UNITED STATES OF AMERICA 

 DEPARTMENT OF ENERGY 

 

NOTICE OF ROPOSED RULEMAKING PUBLIC MEETING ON 

RESIDENTIAL FURNACE FANS TEST PROCEDURE 

 

 

U.S. Department of Energy 

1000 Independence Ave., SW 

Washington, D.C. 20585 

 Room 8E-089 Review Center 

 

 Friday 

June 15, 2012 

 

Facilitator: 

Doug Brookman 

Public Solutions 

Baltimore, MD 
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Participants Identified: 

Brian James 

Southern California Edison 

Adam Christiansen 

Appliance Standards Awareness Project 

Harvey Sachs 

American Council for an Energy Efficient Economy 

Charlie Stephens 

Northwest Energy Efficiency Alliance 

Meg Waltner 

Natural Resources Defense Council 

Dave Wittingham 

Allied Air, Lennox 

Greg Wagner 

Morrison Products 

Terry Small 

Mortex 

Craig Messmer 

Unico, Incorporated 

Michelle Cox 

... Blake Corporation 

Aniruddh Roy 

Air Conditioning, Heating, and Refrigeration Institute 

Frank Stanonik 

AHRI 

Rachelle Cocks 

Regal Beloit 
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Participants from DOE:

Eric Stas 

DOE General Counsel’s Office 

Mohammed Khan 

DOE 

Jim Raba 

Department of Energy 

Brenda Edwards 

Department of Energy 

 

Participants from Consultants:

Sam Jasinski 

Navigant Consulting Incorporated 

Alex Lekov 

Lawrence Berkeley National Laboratory 

Detlef Westphalen 

Navigant Consulting 

Heather Keil 

Navigant Consulting 
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AGENDA

 ITEM PAGE 

 

Welcome, Doug Brookman 5 

Welcome for DOE, Mr. Khan 5 

Introductions 6 

Agenda Review, Doug Brookman 8 

Introductory Remarks and Overview 

 Mr. Kahn 10 

Opening Statements 15 

Scope of Applicability, Mr. Jasinski 24 

Reference Standards and Test Methods 

 Mr. Jasinski 29 

Fan Efficiency Rating, Methodology and 

Calculation, Mr. Jasinski 104 

 

Rating Examples, Mr. Jasinski 206 

 

Certification, Compliance, and 

Enforcement Overview, Mr. Westphalen 215 

 

Final Comments of interested parties 231 

Closing Remarks, Mr. Khan 242 
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Please take your seats. 

3 Good morning everyone and welcome. This is the U.S. 

4 Department of Energy’s Notice of Proposed Rulemaking 

5 Public Meeting on Residential Furnace Fans Test 

6 Procedure. Today is Friday, June 15, 2012 here in 

7 the Department of Energy in Washington, D.C. My 

8 name is Doug Brookman from Public Solutions in 

9 Baltimore. 

10 We’re going to start off this morning with 

11 welcoming remarks from Mohammed Khan. 

12 Welcoming Remarks 

13 MR. KHAN: Good morning everybody. My 

14 name’s Mohammed Khan, Project Manager for this 

15 rulemaking activity. I just want to first say thank 

16 you. Really appreciate your attendance today for 

17 this important meeting. As many of you are probably 

18 aware, the rulemakings that we have done recently 

19 for new standards and such are basically amendments 

20 to existing standards and also test procedures. 

21 This one however, is a bit different. There 

22 currently is not a test procedure in place. There 

23 is also no standard in place. So that makes this 
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1 one unique. It’s also unique in the sense that the 

2 product that we’re talking about today, residential 

3 furnace fans, is a component of a product that we 

4 already regulate. So it’s different in that sense 

5 as well. 

6 So because of all of that, your comments 

7 and concerns and particularly written comments that 

8 you might want to submit later will be very, very 

9 beneficial to us. So I look forward to a good 

10 discussion. Thanks. 

11 MR. BROOKMAN: Thank you. It’s our 

12 tradition to start with introductions. So I’ll 

13 start to my immediate left. Please say your name 

14 and organizational affiliation, and also you can get 

15 used to turning the microphone on and off as you 

16 speak, please 

17 Introductions 

18 MR. JAMES: Brian James, Southern 

19 California Edison. 

20 MR. CHRISTIANSEN: Good morning. Adam 

21 Christiansen from the Appliance Standards Awareness 

22 Project. 

23 MR. SACHS: Harvey Sachs, American Council 

24 for an Energy Efficient Economy. 

25 MR. STEPHENS: Charlie Stephens, Northwest 
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1 Energy Efficiency Alliance. 

2 MS. WALTNER: Meg Waltner, Natural 

3 Resources Defense Council. 

4 MR. WITTINGHAM: Dave Wittingham, Allied 

5 Air, Lennox. 

6 MR. WAGNER: Greg Wagner, Morrison 

7 Products. 

8 MR. SMALL: Terry Small, Mortex. 

9 MR. MESSMER: Craig Messmer, Unico, 

10 Incorporated. 

11 MS. COX: Michelle Cox, ... Blake 

12 Corporation. 

13 MR. ROY: My name is Aniruddh Roy, Air 

14 Conditioning, Heating, and Refrigeration Institute. 

15 MR. STAS: Eric Stas, DOE General 

16 Counsel’s Office. 

17 MR. KHAN: Mohammed Khan, DOE. 

18 MR. WESTPHALEN: Detlef Westphalen, 

19 Navigant Consulting. 

20 MR. JASINSKI: Sam Jasinski, Navigant 

21 Consulting Incorporated. 

22 MR. LEKOV: Alex Lekov, Lawrence Berkeley 

23 National Laboratory. 

24 MR. BROOKMAN: Thank you. Please. 

25 MS. KEIL: Heather Keil, Navigant 
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1 Consulting. 

2 MR. BROOKMAN: Jim? 

3 MR. RABA: Jim Raba, Department of Energy. 

4 MR. BROOKMAN: Once again, thanks to all 

5 of you for being here and giving us a timely start 

6 on the meeting today. 

7 Agenda Review

8 MR. BROOKMAN: I’m going to do a very 

9 brief agenda review. As you can see, all of you 

10 received a packet of information as you came in the 

11 door today. If you have not yet handed off a 

12 business card to Brenda Edwards, please do so 

13 because the Department typically would make a 

14 photocopy of all the attendees and make it available 

15 to everyone here. 

16 Immediately following this agenda review 

17 Mohammed’s going to provide an overview, talking 

18 about the purpose of the meeting, comments 

19 submission instructions, regulatory authority and 

20 other rulemaking overview matters. Immediately 

21 following that, we’ll have scope of applicability of 

22 reference standards and test methods by Sam. 

23 We’ll take a break mid-morning, round 

24 about 10:45 or so. Returning from the break, fan 

25 efficiency rating methodology and calculation. 
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1 Around about 12:30 or so, we’ll take lunch 

2 around. When we return from lunch, rating examples 

3 and comparison, and then following that, 

4 certification compliance and enforcement overview. 

5 There is an opportunity at the end of the 

6 day for additional remarks, closing remarks from 

7 anyone who wishes to do so, and as soon as Mohammed 

8 finishes his slides, his introductory slides, there 

9 is an opportunity at that point for anybody that 

10 wants to make opening statements, draw attention to 

11 issues from your perspective here at the outset. 

12 I’d ask for your consideration. Please 

13 speak one at a time. We’ve -- the Department has 

14 tried to make these meetings accessible to folks via 

15 the web, and we’re getting more and more folks 

16 joining via the web, which means we need to be a 

17 little more disciplined about using the microphones. 

18 We need to turn them on and off each time we speak, 

19 because what we’ve heard is that if you leave them 

20 on, then it provides feedback in the system. So I’m 

21 going to be trying to remind you to do that as the 

22 day goes on today. 

23 If you would, please speak one at a time. 

24 Turn the mics on and off. Say your name for the 

25 record each time you speak. You don’t need to say 
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1 your organizational affiliation unless that’s what 

2 you would like to do. I’m going to be cuing 

3 individuals by name to speak. There will be a 

4 complete transcript of this meeting posted on the 

5 DOE website. I’m going to be cuing individuals by 

6 name as best I can to speak. I also wish to 

7 encourage follow on comments, the back and forth is 

8 sometimes very useful to the Department as they try 

9 and figure out what the best pathway is. 

10 If you please be concise. Share the air 

11 time. And if you keep the focus here, turn your 

12 cell phones on silent mode, limit sidebar 

13 conversations if you can, and we’ll have a very 

14 productive meeting. Questions and comments here at 

15 the outset? Okay, then, to Mohammed Khan. 

16 Overview. 

17 Overview 

18 MR. KHAN: Thanks. Good morning everyone. 

19 Welcome, and thank you for participating in today’s 

20 meeting on the U.S. Department of Energy’s proposed 

21 test procedure for residential furnace fans. My 

22 name’s Mohammed Khan and I’m the project manager for 

23 this rulemaking activity. 

24 Today’s meeting serves multiple purposes. 

25 Mainly, our goal is to have a two-way discussion. 
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1 We want to convey the key points and concepts 

2 associated with this rulemaking, as well as to hear 

3 and listen to your thoughts and potential concerns. 

4  So first the Department wants to present its 

5 approaches for a furnace fan test procedure. 

6  Second, DOE is seeking comments on its 

7 proposed test procedure. 

8  This is also a forum for all interested 

9 parties to hear and discuss issues raised by 

10 others. 

11  And again, because your feedback is very 

12 important, I encourage everyone to fully 

13 participate and urge that you submit any 

14 relevant data that might aid the Department 

15 in developing the best possible test 

16 procedure. 

17  And lastly, we want to describe the steps in 

18 the rulemaking process. 

19 Comments. Your comments are essential to 

20 the success of this rulemaking. All participants 

21 are encouraged to submit summary comments and 

22 raise any additional issues relevant to the rule, 

23 and as indicated in the NOPR, which was published 

24 one month ago, the close of comment period is 
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July 30th 1 . 

2 This slide represents a sample of the call 

3 out boxes we will use throughout our presentation to 

4 identify certain issues the Department seeks 

5 detailed information on. And for reference, please 

6 note that numbering of the issues boxes correspond 

7 to the issues listed in the NOPR. 

8 As I mentioned earlier, feedback is very 

9 important to the Department and I want to make sure 

10 everyone is clear on how to submit the comments. 

11 This slide provides the postal, courier, and e-mail 

12 addresses which are appropriate for submitting the 

13 comments. Please include the information here at 

14 the top so that your comment is properly identified 

15 and catalogued. While not provided on this slide, 

16 you also can submit, via www.regulations.gov, your 

17 comments. Regulations.gov is a new online tool for 

18 submitting comments on all federal government 

19 proposed rules. Let me also point out again, the 

comment period ends on the 30th 20 of July 

21 This slide outlines the meeting agenda. 

22 Following my introduction and overview, we will 

23 discuss the scope of applicability. Next we will 

24 take a look at the applicable reference standards 

25 and the sections of those standards that are 
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1 considered relevant. Next we’ll describe the 

2 parameters that are in the FER and look at some 

3 examples and how that applies to different kinds of 

4 products. And before closing remarks, in the last 

5 section of the presentation, we’ll consider a 

6 possible approach for certification, compliance and 

7 enforcement. 

8 The Energy Policy and Conservation Act 

9 directs DOE to establish test procedures for furnace 

10 fans and at 42USC6293.B.3, EPCA charges DOE to 

11 promulgate standards for furnace fans by December 

12 2013. EPCA also says that test procedures must be 

13 reasonably designed to produce test results which 

14 reflect the energy efficiency or energy consumption 

15 of a product during a representative average use 

16 cycle, and shall not be unduly burdensome to 

17 conduct. 

18 The final point on this slide is that the 

19 furnace fan test procedure must also account for 

20 standby mode and off mode energy use. EPCA, after 

21 being amended in 2007 by the Energy Independence and 

22 Security Act, requires that the energy use 

23 associated with standby mode and off mode be 

24 integrated into the energy conservation standard 

25 unless the existing standard already accounts for 
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1 them or integration is not technically feasible. If 

2 integration is not technically feasible, EPCA 

3 requires separate standards for standby mode and off 

4 mode energy use. 

5 Okay. As I said at the outset of our 

6 meeting, there’s currently no test procedure or 

7 standard for the furnace fans. DOE kicked off the 

8 furnace fan effort with a framework document for 

9 standards in June 2010. 

10 So, where are we today in our rulemaking 

11 process? Last month DOE published its NOPR for the 

12 furnace fan test procedure. Today we’re holding the 

13 public meeting to receive your input. Again, I 

14 cannot over-emphasize the importance of your verbal 

15 and written comments. And once again, please submit 

16 comments and any relevant data by the deadline. 

17 In developing the final rule, DOE will 

18 carefully review the transcript of today’s meeting, 

19 together with all comments that it receives, and we 

20 anticipate issuance of the final rule by December 

31st 21 . 

22 So at this time, as Doug mentioned before, 

23 if there are any opening remarks by anyone? 

24 MR. BROOKMAN: Yes, briefly before we do 

25 that, I want to also extend a welcome to those that 
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1 are joining us via the web. The Department of 

2 Energy is trying hard to make these meetings 

3 accessible and successful via the web, and they are 

4 hoping that if you’re joining via the phone you can 

5 submit questions or comments by raising your hand in 

6 the “go to meeting” software or via “go to meeting”, 

7 use the question window in the “go to meeting” to 

8 submit a question that will be relayed to me, the 

9 moderator, and we’ll try very hard to incorporate 

10 those comments and questions during the flow of the 

11 meeting itself, and that will be a part of the 

12 transcript, the record of the meeting. So welcome 

13 to those joining us via the web. How many do we 

14 have joining us via the web? Twenty-two, it’s a lot 

15 of carbon saved. 

16 So then opening statements here at the 

17 outset? Yes, please. Your name. 

18 Opening Statements 

19 MR. ROY: My name is Roy, AHRI. Our 

20 opening statement is the scope of this NOPR does not 

21 follow the original intent of the Energy Policy and 

22 Conservation Act. The test procedures should have 

23 been limited to fans within residential furnaces 

24 only. Also the proposed reference system in the 

25 NOPR specifies external static pressures that are 
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1 too high as compared to the external static 

2 pressures in the federal test procedure for furnaces 

3 that are currently in place. Hence, this NOPR 

4 essentially leads to different external static 

5 pressures for measuring AFUE and FER for residential 

6 furnaces. 

7 We also feel that DOE should consider 

8 adopting the e-sub-b metric that our industry 

9 proposed earlier, since it allows for relative 

10 electrical performance comparison of furnace fan 

11 without imposing unnecessary burden of air flow 

12 measurement at additional external static pressures. 

13 MR. BROOKMAN: Thank you. Other comments 

14 here at the outset? Harvey Sachs. 

15 MR. SACHS: Harvey Sachs, American Council 

16 for an Energy Efficient Economy. I am disappointed. 

17 I am disappointed because the plain text of the 

18 42USC reference Mr. Khan has given us says that we 

19 shall have standards for electricity use for 

20 purposes of circulating air through duct work, 

21 hereinafter referred to as furnace fans. On the 

22 very most minor level, I’m disappointed that this 

23 document, the test procedures doesn’t have a 

24 definition of furnace fans that I found. I did find 

25 it in the RFI. We did comment on it at that time. 
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1 And despite what I regard as fairly clear 

2 instruction from Congress, although there is some 

3 ambiguity and we recognize that, the Department has 

4 chosen, as far as I can tell, to construe the 

5 requirement as being a narrow box around the sheet 

6 metal, its motor, impeller, and the shroud. The 

7 Department’s own research carried out by Ian Walker 

8 over a period of years, the LBL, has I think 

9 demonstrated fairly clearly that a large fraction of 

10 the electricity consumption of these devices has to 

11 do with the aerodynamics of the air handler cabinet. 

12 That, as one simple example, if within a 

13 product family, however we define that, we choose to 

14 use a longer fan within the same cabinet as other 

15 models might have a shorter fan, we’ve dramatically 

16 reduced the clearances between the inlet to the box 

17 and the fan itself. This does not make moving air 

18 happy. Consequently, we proposed earlier, that the 

19 unit of interest is the air handler, a virtual 

20 appliance. Ironically, were we to treat it as the 

21 air handler, this would completely remove the 

22 concerns that Roy has expressed on AHRI’s behalf, 

23 because we now would have an electricity measurement 

24 for air handling without having to touch either the 

25 furnace or the air conditioner rating method. 
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1 We all know that for 30 years we have used 

2 a really unrealistic, mythological set of values for 

3 external static in the air conditioner test 

4 procedure. If we want to have any kind of realism, 

5 anything better than relative values, anything that 

6 will be use of modelers and specifiers -- for 

7 modelers and specifiers -- we need to do something 

8 about this. And a smart rule on air handlers would 

9 give us the ability to capture that without having 

10 to retest the hundreds of thousands of air 

11 conditioner models that are out there. 

12 So I have a sense that proceeding down 

13 this track is a missed opportunity. Now, the 

14 regulations also require that this shall be 

15 reasonably designed to produce test results which 

16 reflect the energy efficiency or energy use of a 

17 product. And I think there’s an affirmative 

18 obligation that the Department has to show that just 

19 looking at the shrouded fan will give realistic 

20 results, given the results that the Department’s own 

21 research has shown. And I don’t think we’re meeting 

22 that burden. So I think we’re going down the wrong 

23 track, and I think it’s going down the track that 

24 will impose a fair amount of burden on people to 

25 make almost totally irrelevant measurements. 
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1 So, other than that, I like everything you 

2 all have done. 

3 MR. BROOKMAN: Thank you. Other comments 

4 here at the outset? I was wondering, Roy -- may I 

5 call you Roy? 

6 MR. ROY: Yes. 

7 MR. BROOKMAN: Since Harvey referenced 

8 your comments at the outset, do you want to respond 

9 to what he just said? No? Not at this time. 

10 MR. ROY: Not at this time. 

11 MR. BROOKMAN: Perhaps in writing. Yes. 

12 Okay. So -- Harvey. 

13 MR. SACHS: This is Harvey Sachs. I will 

14 certainly provide comments, but please send me an e15 mail to remind me so you all have time to play with 

16 them. Thank you. 

17 MR. BROOKMAN: Yes, please. Craig 

18 Messmer. 

19 MR. MESSMER: Yes, I’d like to take this 

20 opportunity to once again ask the Department to 

21 please consider the small duct high velocity 

22 classification. 

23 MR. BROOKMAN: Hang on just one second, 

24 okay. I didn’t hear that last thing, so would you 

25 say it again, please? 
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1 MR. MESSMER: You’re right. Hello. This 

2 is Craig Messmer. We make small duct high velocity 

3 equipment and this particular NOPR does not include 

4 any language for small duct high velocity. We 

5 operate at much higher static pressures than 

6 conventional blowers. And to Harvey’s point, I 

7 think we actually have pretty realistic values in 

8 our test standards, so I would like the Department 

9 please consider that in the rulemaking. 

10 MR. BROOKMAN: Okay. Thank you. I think 

11 it’s especially helpful here at the outset to hear 

12 from members of the industry if they have anything 

13 to say at this point. Yes, Dave. 

14 MR. WITTINGHAM: Yes, this is Dave 

15 Wittingham from Allied Air, Lennox. Just to ask the 

16 Department please consider the burden that the test 

17 procedure as outlined will impose upon 

18 manufacturers. Across our organization, we have 

19 hundreds, if not thousands of products that could be 

20 classified as furnace fans, and the time and cost 

21 and ongoing cost of this test procedure as outlined 

22 would be unduly burdensome. 

23 Also, I think, as far as the external 

24 static points that are proposed, there are products 

25 where the proposed static pressures would take the 
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1 product out of its safe and reliable range of 

2 operation, and I think a manufacturer’s intended 

3 installation or safe and reliable operation needs to 

4 be considered in any type of test procedure. Thank 

5 you. 

6 MR. BROOKMAN: Wendy, we got that okay? 

7 Yes. 

8 MR. SMALL: This is Terry Small with 

9 Mortex, and I would like to echo what Dave just 

10 said. We’re a small manufacturer of some of these 

11 products and there would be a disproportional burden 

12 on us. The cost required to initiate the test and 

13 the ongoing cost to perform the test. If you have 

14 fairly burdensome testing spread across tens of 

15 thousands of units, that’s one thing. If you have 

16 burdensome testing spread across -- you know, we 

17 have some products we may only sell 100 or 200 a 

18 year. That is ridiculously burdensome. So I’d just 

19 stress that this needs to take into account the full 

20 array of manufacturers of this type of product in 

21 terms of coming up with the test procedure that is 

22 administratable and performable. 

23 MR. BROOKMAN: Thank you. I’m sure those 

24 of you that are familiar with these DOE proceedings 

25 realize they’re on a constant quest for data. And 
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1 so your data, related to the burdens that you’re 

2 likely to face, as your project this test procedure, 

3 will be very helpful to them, so sooner rather than 

4 later, and in detail will be helpful to the 

5 Department. Okay. Harvey. 

6 MR. SACHS: Harvey Sachs, ACEEE and I want 

7 to reflect Dave Wittingham’s comment and I can’t 

8 think of any person who would object to test 

9 procedures that would allow the manufacturer to map 

10 out an installation not recommended zone, so that 

11 his testing would not be as -- would not be 

12 attempted in areas where the product is clearly 

13 unsuitable. That would seem to be a reasonable 

14 accommodation. Exactly how it would have to be 

15 done, I have no idea. 

16 MR. BROOKMAN: Okay. I guess we’re going 

17 to get into -- we will, of course, as the day 

18 progresses, get into considerable detail on the 

19 proposed test procedure. However, it does seem at 

20 the outset at least one person in the room think the 

21 Department’s taking the wrong approach here. So I’m 

22 not sure how we incorporate that, if we stick 

23 entirely with the content that’s here in the 

24 proposed test procedure. So let me just entertain 

25 any additional comments on that score right now? 
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1 Nothing additional at this time. Okay. Just 

2 thought I’d try. 

3 We have a comment, and hopefully this will 

4 work, someone who’s joined us via the web, Jim 

5 Vershaw is joining us via Go To Meeting, I guess. 

6 Jim, we hope to hear you speak. If you unmute your 

7 phone or line. 

8 MR. VERSHAW: How’s that? 

9 MR. BROOKMAN: That’s good. We’re hearing 

10 you. Speak loudly. 

11 MR. VERSHAW: I guess as we look at this, 

12 we’re having a hard time seeing -- well, there’s a 

13 feedback, I’m not sure -- 

14 MR. BROOKMAN: We can hear you okay. Just 

15 keep going. 

16 MR. VERSHAW: Okay. It’s hard to 

17 determine how the homeowner or consumer would use 

18 this metric in order to make a purchase considering 

19 that it includes electricity that’s already put in 

20 the heater or the air conditioner, and is -- the 

21 testing is done with test procedures that are 

22 different than the other tests are put in. It 

23 includes the ... that most people don’t use, and is a 

24 very difficult scripture to understand. It’s hard 

25 enough to understand FER and HSPF and AFUE. But 
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1 this is one of the struggles we’re having. It also 

2 uses a test procedure from ASHRAE, the air 

3 conditioning use ... so it’s a lot to deal with. 

4 Thanks. 

5 MR. BROOKMAN: Okay. So we’re about to 

6 move into the more detailed content in the slide 

7 packet. Final comments here at the outset before we 

8 turn it over to Sam? Okay. Sam Jasinski. 

9 Scope of Applicability 

10 MR. JASINSKI: Good morning. I’ve had the 

11 pleasure of meeting some of you in previous -- the 

12 framework public meeting and maybe some other 

13 rulemakings, but for those of you who don’t know me, 

14 my name is Sam Jasinski from Navigant Consulting, 

15 and I’ve been working on the furnace fan rule pretty 

16 much since its inception. 

17 So to start off, I will begin by providing 

18 an overview of the Scope of Applicability of today’s 

19 proposed test procedure. Pursuant to the EPCA 

20 language that Mohammed described earlier, the Scope 

21 of Applicability of this proposed test procedure is 

22 single phase, electrically powered devices that are 

23 used to circulate air through ductwork in heating, 

24 ventilation and air conditioning products, with 

25 heating capacities that are less than 250,000 BTU 
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1 per hour, and coolant capacities that are less than 

2 65,000 BTU per hour. 

3 You’ll notice that these criteria are 

4 consistent with the current DOE definitions for 

5 residential furnace and residential central air 

6 conditioners. DOE finds that HVAC products that 

7 meet these criteria, typically have air flow 

8 capacities that are less than 3000 cfm, which is 

9 cubic feet per minute. In addition, DOE proposes to 

10 exclude any non-ducted products which include whole 

11 house ventilation systems that don’t have duct work, 

12 CAC condensing unit fans, room fans, and the furnace 

13 inducer fans -- draft inducer fans. 

14 Before I move on, does anybody have any 

15 questions or comments regarding the Scope of 

16 Applicability or proposed Scope of Applicability? 

17 MR. WAGNER: Yes. 

18 MR. BROOKMAN: Greg. 

19 MR. WAGNER: Yes, I would just say that 

20 back to the definition -- 

21 MR. BROOKMAN: Get close to the 

22 microphone, Greg. 

23 MR. WAGNER: Back to the definition. This 

24 is different than what was outlined under the 

25 legislation, the EPCA. In 6295F, it clearly defines 
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1 furnaces as what they are and this is different than 

2 what was included in that language. 

3 MR. BROOKMAN: Can you say how it’s 

4 different? 

5 MR. WAGNER: It clearly says that it’s for 

6 furnaces and boilers. It doesn’t include central 

7 air conditioners. And it excludes certain other 

8 items that want to be included in the scope of this. 

9 MR. BROOKMAN: Okay. 

10 MR. WAGNER: So if you go back to the 

11 language of that, particularly under 4D, it covers 

12 that, and we’ve commented on this before and will 

13 supply those comments again, but it’s expanded 

14 beyond what was originally written in the 

15 legislation. 

16 MR. BROOKMAN: Okay. Roy? 

17 MR. ROY: I Support what Greg Wagner is 

18 saying. Again, Aniruddh Roy with AHRI. If you look 

19 at the title of 42USC 6295F, it says, “Standards for 

20 furnaces and boilers.” And we feel that just the 

21 heading and all the sub notes that follow, 

22 everything covers either furnaces or boilers, and 

23 the last sentence, D, is what’s being referenced, 

24 and we feel that what’s being told to us in terms of 

25 the Scope of Applicability just pertains to 
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1 residential furnaces only. 

2 MR. BROOKMAN: Okay. Thanks for 

3 remembering to turn off the microphones. That 

4 helps. Dave, do you have a comment here? No. 

5 Additional comments before we move on? Okay. 

6 Reference Standards and Test Methods 

7 MR. JASINSKI: Thank you. Next I’ll 

8 describe some of the primary reference standards 

9 that we are incorporating by reference in the 

10 proposed test procedure. In the framework document, 

11 and in the framework public meeting, a large focus 

12 of the discussion relevant to the test procedures 

13 focused on identifying and finding relevant existing 

14 industry standards. In comments from the framework 

15 document meeting, and in subsequent work by DOE and 

16 subsequent conversations with industry participants, 

17 we’ve identified ANSI/AMCA 210-07 as a standard 

18 that’s very well known and used industry-wide to 

19 measure performance of furnace fans. So for that 

20 reason, DOE is proposing to incorporate by reference 

21 ANSI/AMCA 210-07 to measure the active mode 

22 performance of furnace fans in this test procedure. 

23 And as Mohammed described earlier, EPCA 

24 also requires that we consider standby and off mode 

25 electrical consumption, so for that reason we also 
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1 have to establish -- DOE is also proposing to 

2 establish DOE-established test methods for measuring 

3 the standby and off mode electrical consumption of 

4 certain products that this test procedure would be 

5 applicable to. There’s a little bit of a spoiler 

6 here in the parenthetical for hydronic air handlers 

7 only. As we’ll get into detail a little bit later, 

8 DOE is already considering and covering standby and 

9 off mode electrical consumption in other rulemaking 

10 activities for some products that would meet the 

11 criteria outlined previously for this test 

12 procedure. 

13 MR. BROOKMAN: Craig. 

14 MR. MESSMER: Hello, this is Craig 

15 Messmer. I’m hoping you do elaborate more on why 

16 it’s just hydronic air handlers that have this. I 

17 understand the gas furnaces are already measuring 

18 this in another way. I wonder why they just didn’t 

19 have the same metric, FER, for everyone that 

20 includes the standby and the off mode. So will that 

21 be answered later? 

22 MR. JASINSKI: Well, I will mention it. 

23 If you look at the sub bullets here, the proposed 

24 reference standard for the hydronic air handlers 

25 will be to adopt the DOE standby and off mode test 
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1 procedure already in place or being finalized for 

2 residential furnaces, which incorporates by 

3 reference, the IEC standard 62-301, second edition. 

4 But we will go into a little bit more detail about 

5 the specifics of the rulemaking activities that are 

6 applicable to standby and off mode for these 

7 products. 

8 MR. BROOKMAN: Charlie Stephens, and Jim 

9 Vershaw is next in the queue. Charlie. 

10 MR. STEPHENS: Charlie Stephens. I’m a 

11 little confused here by what seems to be a bit of a 

12 schizophrenic approach to what the covered product 

13 is. I’m not sure how we leap from furnace fans to 

14 air handlers here. I can understand standby energy 

15 use by an air handler. I think that’s pretty much 

16 the case, a furnace or an indoor unit for a heat 

17 pump system or a hydronic air handler. But I’m not 

18 sure that applies to a furnace fan. It seems to me 

19 that the product here -- it’s either an air handler 

20 or it’s a furnace fan, and DOE has gone to some 

21 trouble to exclude including air handlers and yet 

22 here we’re doing standby power for an air handler, 

23 and I have to admit to being a little confused by 

24 that. 

25 MR. BROOKMAN: Okay. Thank you. 
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1 MR. JASINSKI: Can I -- just a follow up 

2 question for that, Charlie. Would you mind just 

3 kind of providing, since it is a new rule and there 

4 aren’t really established standard industry 

5 definitions for a lot of the things that we might be 

6 talking about, can you kind of provide your 

7 distinction between an air handler versus a furnace 

8 fan and so forth, just so everybody can really 

9 understand the comment. 

10 MR. STEPHENS: Sure. Charlie Stephens. I 

11 kind of regard the furnace fan as a component of an 

12 air handler, kind of like a pump is a component of a 

13 clothes washer. It’s -- the clothes washer has 

14 standby energy consumption, but the pump probably 

15 doesn’t. It’s a -- that’s the kind of distinction 

16 I’m making here, and I think we recommended in our 

17 comments in the original framework proceeding, that 

18 air handlers be considered the covered product, and 

19 it seems DOE has gone out of their way not to 

20 consider air handlers the covered product, and has 

21 resorted to a fairly simple, including their 

22 diagrams, of a furnace fan as not an air handler. 

23 And so I’m trying to understand why, in a furnace 

24 fan rulemaking, when they’ve done that, we’re now 

25 considering standby and off mode for an air handler, 
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1 any kind of air handler. 

2 MR. BROOKMAN: Okay. Jim Vershaw is next. 

3 Jim, unmute your machine, and talk loudly. 

4 MR. VERSHAW: Okay. Talk loudly. All 

5 right. Jim Vershaw, Ingersoll Rand. The first 

6 comment I have has to do with the ASHRAE 51. It was 

7 stated that that was used for furnace fans, and I 

8 would disagree with that. If you look at the test 

9 procedures that are required for air conditioning 

10 and heat pump ... AHRI has authority, which 

11 incorporates ASHRAE 37, ASHRAE 37 does incorporate 

12 part of ASHRAE 51. However, the way the equipment 

13 is -- the ductwork -- the way the static pressure is 

14 measured, is totally ..., and if we continue down this 

15 path using 51, we’re going to have to -- all the 

16 data we currently have on our books won’t be 

17 applicable. We’ll have to redo all of it. And I 

18 don’t think that the way the equipment is used is 

19 primarily conductive, you don’t have to worry about 

20 velocity pressures at a later time. So that’s a 

21 real issue for us, and I think you need to 

22 reconsider using 51 for this testing. 

23 As far as standby power goes, one of the 

24 interesting things that happens with standby power 

25 is you go to high efficiency motors and all of a 
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1 sudden your motor has standby power because there’s 

2 electronics, so there’s kind of a catch-22 on this 

3 whole thing. Thank you. 

4 MR. BROOKMAN: Jim, are you finished? So 

5 Jim, you had addressed both scope issues and the 

6 burden issue, so I’m certain the Department would 

7 appreciate your detailed comments in writing. 

8 MR. JASINSKI: I also just have a quick 

9 follow up for Jim. My question is sort of a 

10 clarifying one. Jim brings up that to test air 

11 conditioners they use, I think he mentioned 

12 ANSI/AMCA 210-240 which references ASHRAE 37. One 

13 distinction or clarification I’d like to make is 

14 that while those products may be tested to -- 

15 according to those reference standards, a lot of the 

16 product literature provides information about the 

17 performance of fans used in the products mentioned. 

18 And it’s DOE’s understanding, based on comments from 

19 the framework document, and also footnotes in some 

20 of the -- a lot of the product literature, that 

21 those -- that that data which is usually in the form 

22 of air flow measurements across a range of external 

23 static pressures, that those are provided in accord 

24 with -- or measured and provided in accordance with 

25 ANSI/AMCA 210. I was just wondering if Jim and 
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1 other manufacturers in the room could either confirm 

2 or correct me if I’m wrong about that. 

3 MR. BROOKMAN: Jim, you want to start with 

4 that? 

5 MR. VERSHAW: Hi. Jim Vershaw here. The 

6 nozzles and the plenum, and the way that the air 

7 flow is measured is the same whether it’s 37 or 51. 

8 the way you measure static pressure according to 

9 units of what the nozzles -- and we follow both 37 

10 for ours, even though we do do a sweep of static 

11 pressures and flow. 

12 MR. JASINSKI: Okay. Thank you. 

13 MR. BROOKMAN: Other comments? Yes, Greg. 

14 MR. WAGNER: Greg Wagner. AMCA 210 is for 

15 testing of fans, and not for appliances. I believe 

16 you’re trying to capture the energy use and 

17 performance of appliances here, and that’s where 

18 this difference lies. ASHRAE 37 is done for the 

19 testing of appliances and would be more apropos to 

20 this type of a setup. 

21 MR. BROOKMAN: Thank you. 

22 MR. WAGNER: And that’s what they tested, 

23 by the way. 

24 MR. BROOKMAN: Okay. Thanks. Do you have 

25 any questions? 
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1 MR. JASINSKI: No. Any other comments or 

2 questions before I move on. Okay. So in these 

3 subsequent slides I’ll talk in a little more detail 

4 about exactly which parts of ANSI/AMCA 210 DOE is 

5 proposing to incorporate by reference. 

6 DOE is proposing to incorporate by 

7 reference only the sections of ANSI 210 that are 

8 required to calculate the proposed metric, which is 

9 the fan efficiency metric, or I’ll refer to it as 

10 FER, and I’ll get into more details about the 

11 specifics of the metric later. 

12 The sections that DOE is proposing to 

13 incorporate and exclude are listed here. I won’t 

14 read all of them to you, because you have them for 

15 reference, but the main take-away here is that the 

16 sections that DOE is not incorporating are related 

17 to the mechanical measurement of fan input power. 

18 ANSI/AMCA 210 has provisions that measure fan input 

19 power using a dynamometer and other mechanical 

20 methods. And in the proposed test procedure, the 

21 DOE proposed test procedure, we are actually going 

22 to -- DOE is proposing to make modifications and 

23 additions to replace those methods, as well as some 

24 other additions. 

25 So the additions that DOE is proposing to 
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1 make to ANSI/AMCA 210: 

2  First, to specify the range in increments of 

3 external static pressure at which 

4 determinations are made. ANSI/AMCA 210 

5 defines the determination as a complete set 

6 of measurements at a given operating point. 

7 For the purposes of the proposed test, DOE 

8 proposed test procedure, a determination 

9 includes the measurement of air flow, 

10 electrical energy consumption or input power 

11 to the furnace fan, as well as external 

12 static pressure. So any time you hear me 

13 refer to a determination, I’m referring to 

14 that set of three measurements which are 

15 used to describe the performance of the fan 

16 at a certain operating point. 

17  Secondly, DOE is proposing to add a 

18 specification for measuring the input power 

19 to the furnace fan using an electrical meter 

20 with a plus or minus one percent accuracy of 

21 observed readings. And as I mentioned 

22 before, those are mainly to replace the 

23 methods in Section 4.4 of ANSI/AMCA 210 that 

24 are mainly mechanical methods of measuring 
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1 input power. 

2  And lastly, we’re adding -- DOE is proposing 

3 to add the specification of an electrical 

4 supply that is maintained within one percent 

5 of the highest nameplate voltage. There are 

6 some products that meet the criteria for the 

7 Scope of Applicability that may have two 

8 nameplate voltages, one at 230, one at 208, 

9 and this just specifies that it be 

10 maintained at one percent of the higher. So 

11 230 in that case. 

12 Do we have any other comments or questions 

13 before I get into the specific requests for comments 

14 that DOE has. 

15 MR. BROOKMAN: Yes, Adam, you’re next. 

16 MR. CHRISTIANSEN: This is Adam 

17 Christiansen from the Appliance Standards Awareness 

18 Project. Just so I’m clear of where the boundaries 

19 for the measurement is occurring. AMCA 210 uses, as 

20 you mentioned, the mechanical means of input power, 

21 the shaft power to the fan. But it also a part of 

22 that test procedure that you can calibrate the motor 

23 in order to measure electrical input power, but 

24 transform that measurement into a mechanical shaft 
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1 power. 

2 MR. JASINSKI: Sure. 

3 MR. CHRISTIANSEN: Is the Department 

4 suggesting that kind of calibration of the motor as 

5 well? 

6 MR. JASINSKI: No, that would be part of 

7 Section 4.4 and 4.5 which DOE is excluding. 

8 MR. CHRISTIANSEN: So you’re going from 

9 the wires to the air pressure valve, that’s the kind 

10 of measurement you’re talking about here. 

11 MR. JASINSKI: The product itself would be 

12 metered. The input power to the product would be 

13 metered, yes. 

14 MR. CHRISTIANSEN: Thanks. 

15 MR. JASINSKI: Any others? 

16 MR. BROOKMAN: Brian. 

17 MR. JAMES: Brian James, California 

18 Edison. Just to be clear, when you have like ECM 

19 motors, that’s going to provide the potential, in 

20 some circumstances, some THD values that will throw 

21 off a standard electrical meter, and so there’s 

22 certain meters that can handle that, and you’ll 

23 still obtain the plus or minus one percent accuracy. 

24 But there are other meters that you’re accuracy is 

25 going to be totally thrown off and your measurements 
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1 are going to be useless if you have a THD as a 

2 result. So just -- a THD, a total harmonic 

3 distortion for that. 

4 MR. JASINSKI: Can you provide maybe a 

5 suggested tolerance or accuracy that should be 

6 included in the specification to avoid any issues 

7 with that? 

8 MR. JAMES: Yeah, we can submit that in 

9 our comments. 

10 MR. JASINSKI: Okay. Thank you. 

11 MR. BROOKMAN: I guess both of the last 

12 two comments you were kind of questioning what I 

13 thought was essentially the method, so detailed 

14 comments on that would be very helpful. 

15 MR. JASINSKI: Any others? 

16 MR. BROOKMAN: Yes, Greg. 

17 MR. WAGNER: The difference, again, in the 

18 210 versus the equivalent ASHRAE 37, they have 

19 velocity pressure difference and doing those 

20 calculations et cetera, are just unnecessarily -- 

21 makes it complex and the ASHRAE 37 has a method for 

22 doing a straight pressure method, which simplifies 

23 this methodology. 

24 MR. BROOKMAN: Okay. 

25 MR. JASINSKI: I think Greg provided a 
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1 pretty good segue to an issue that DOE is 

2 specifically requesting comment, and that has to do 

3 with a couple clarifications regarding the 

4 definition of external static pressure. In a lot of 

5 product literature and conversations with industry, 

6 the term external static pressure is used. However, 

7 that term is not defined or explicitly stated in 

8 ANSI/AMCA 210, and DOE is specifically requesting 

9 comment on whether when manufacturers use the term 

10 external static pressure, that they’re actually 

11 referring to what is defined as fan static pressure 

12 in ANSI/AMCA 210. 

13 And I provided here the definition from 

14 ANSI/AMCA 210 of fan static pressure as well as the 

15 proposed definition in the Notice of Proposed 

16 Rulemaking for external static pressure which are 

17 meant to be consistent with one another. 

18 So the first question before going into 

19 details of the definitions is just the clarification 

20 from the industry participants as to whether or not, 

21 when they refer to external static pressure in 

22 product literature, are those values in accordance 

23 with ANSI/AMCA 210’s definition of fan static 

24 pressure? 

25 MR. BROOKMAN: Craig. 
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1 MR. MESSMER: This is Craig Messmer again. 

2 We use ASHRAE 37, which is defined by just the 

3 measure, external static pressure subtracted from 

4 the supply and the return. We do not use AMCA, and 

5 we don’t see any need for that either. We specify 

6 what the duct sizes have to be used for each air 

7 handler and it’s not a fan standard. We’re not -- 

8 MR. JASINSKI: I think the next slide will 

9 provide a little bit of clarification that seems to 

10 be necessary. 

11 MR. BROOKMAN: On this point, on issue 8, 

12 Jim Vershaw has had his hand raised. Jim, you’re 

13 next. And Jim, if you can get close to whatever the 

14 microphone is on your system, you were kind of 

15 breaking up the last time you spoke. No? Jim’s not 

16 on, so we’ll hear from him later, perhaps. Craig, 

17 keep going. 

18 MR. MESSMER: I’d like to make -- this is 

19 Craig Messmer. I want to follow up with what I was 

20 just saying. We compare the two differences in the 

21 equations for external static pressure, and there is 

22 a difference, and there is a significant difference, 

23 and it makes the product look worse than it really 

24 is. So we would again encourage you to use ASHRAE 

25 37. 
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1 MR. JASINSKI: As a follow up to these -- 

2 to Craig’s comment, I will just draw attention to 

3 the part of the definition of external static 

4 pressure that specifies that it’s the difference 

5 between the total pressure at the air outlet and the 

6 total pressure at the air inlet, less the velocity 

7 pressure. And on the next slide, I think this will 

8 help because it provides a little bit more 

9 visualization of exactly what we’re describing. 

10 And I think, to Harvey’s comment earlier, 

11 as well as some other comments about wrapping our 

12 heads around exactly the Scope of Applicability and 

13 the scope of the measurement, so to speak, you’ll 

14 see in the diagram here -- this is Figure 12 from 

15 ANSI/AMCA 210, and this is the test setup that DOE 

16 finds is very popular for taking the types of 

17 measurements that we’re describing in this test 

18 method. And you’ll see all the way to the left, a 

19 box labeled “fan,” and I think a lot of confusion 

20 results from the fact that maybe -- maybe some 

21 interested parties are misunderstanding that DOE is 

22 not suggesting that the fan component be removed 

23 from the product and tested in this setup. In fact, 

24 the Notice attempts to explicitly state that the fan 

25 be kept inside the HVAC product. So where you see 
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1 fan here, it would probably more appropriate to 

2 label that as HVAC product. And then, so consider 

3 that as either a furnace or a hydronic air handler, 

4 or whatever else -- whatever HVAC product that 

5 incorporates a furnace fan, would be in place of the 

6 fan in this schematic. 

7 And also pay attention to the planes are 

8 labeled at the top, one, two, seven, and five. So 

9 the pressure measurements are actually taken at 

10 plane seven and plane one, and so the scope of the 

11 measurements that a lot of people are referring to 

12 with the modification that I just explained, these 

13 measurements are actually taken outside of the HVAC 

14 product, the product being the entire furnace, or 

15 the entire modular blower, or the entire hydronic 

16 air handler. 

17 So, in fact, when we define and talk about 

18 external static pressure in the context of the 

19 proposed rule, we’re actually talking about the 

20 pressure drop across the entire HVAC product, not 

21 just the fan inlet and the fan outlet which is 

22 interior to the HVAC product, like prior to the heat 

23 exchanger or whatever other appertances may be 

24 downstream within the envelope. 

25 MR. BROOKMAN: Thanks for that 
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1 explanation. Greg first. 

2 MR. WAGNER: I don’t want to speak 

3 completely for the rest of the folks that do this 

4 kind of testing, but I think they understand that 

5 difference. What’s different is that the 210 test 

6 methodology, correction factor, all those things, 

7 are designed for fans themselves. 

8 MR. JASINSKI: Okay. 

9 MR. WAGNER: ASHRAE 37 is designed for 

10 appliances, and it’s a different test standard. 

11 It’s one they conduct today and it makes sense for 

12 that type of an appliance. AMCA 210, ASHREAE 51 

13 makes sense for fan only. But I think they 

14 understand what you’re representing as a unit. 

15 MR. BROOKMAN: So to be explicit, what are 

16 you suggesting the DOE do in this case? 

17 MR. WAGNER: Well, there’s a lot of things 

18 I suggest they do, but -- 

19 MR. BROOKMAN: On this specific issue. 

20 MR. WAGNER: I can echo a lot of things I 

21 already heard earlier today, but in this particular 

22 thing, the 37 is more applicable to what you want to 

23 accomplish along this path, than the 210. 

24 MR. BROOKMAN: Okay. Harvey, you’re next. 

25 MR. SACHS: Sam, that diagram is really 
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1 important, and it has the term fan over there on the 

2 left side, and I think I heard you say that means 

3 air handler, is that correct? 

4 MR. JASINSKI: Well, I’m not trying to 

5 redefine fan. All I’m trying to explain is that in 

6 the proposed DOE test procedure, which incorporates 

7 ANSI/AMCA 210 by reference, in this diagram -- in 

8 the ANSI/AMCA 210 diagram -- it’s the -- the unit 

9 under test is labeled as a fan here, and what I’m 

10 trying to say is that when -- as it states in the 

11 proposed test procedure which can be considered a 

12 modification maybe to the methods that are in 

13 ANSI/AMCA 210, DOE is specifying that the entire 

14 HVAC product be the unit under test, that the fan is 

15 not actually removed from the envelope or the 

16 shroud, as you described it earlier, and then 

17 tested. 

18 MR. SACHS: Sam -- this is Harvey Sachs 

19 again. I will apologize if that language is 

20 actually in either the RFI or in this proposed test 

21 method. I did not find it, and I feel I might have 

22 wasted an entire rant earlier this morning. So this 

23 needs to be -- if this is your intent, it needs to 

24 be very clear, because I think I’m not the only one 

25 in this room who misunderstood what you were 
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1 planning to do. As I read it in the RFI, it was the 

2 motor, the impeller, and the shroud around it. And 

3 I found no other definitions of the scope of this 

4 test method. 

5 MR. JASINSKI: When you refer to the RFI, 

6 are you talking about the framework document? 

7 MR. SACHS: Framework document, I’m sorry. 

8 This is the -- I think I’ll stop. 

9 MR. JASINSKI: Just the -- 

10 MR. BROOKMAN: Well, Harvey -- 

11 MR. JASINSKI: Go ahead, Doug. 

12 MR. BROOKMAN: No, you go ahead, Sam. 

13 MR. JASINSKI: Just kind of a distinction. 

14 In the definitions that are provided in the 

15 framework document -- the framework document is 

16 largely intended as a kickoff for the energy 

17 conservation standard, and we happy to use the 

18 framework document a little bit differently for 

19 furnace fans, because, as Mohammed stated, this is s 

20 somewhat unique rulemaking in that there are no 

21 established test procedures and there’s no current 

22 standard. So the test procedure section and 

23 discussion in the framework was beefed up a lot 

24 because we wanted to use it as an opportunity to get 

25 some preliminary feedback in regard to the test 
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1 methods. So I’ll just say that in definitions in 

2 the framework document, those definitions and Harvey 

3 keeps referring to the specific components that were 

4 listed as typically part of a fan, the intention of 

5 that definition versus the Scope of Applicability of 

6 the test procedure are -- they serve somewhat 

7 different purposes. 

8 MR. SACHS: I’m sorry -- this is Harvey 

9 Sachs again. I’ve just leafed through the test 

10 method again. There is no diagram that would help 

11 me understand what you meant. There is no 

12 definition. And you have asked this community, 

13 including the manufacturers, to invest a great deal 

14 of time to think about what y’all might have been 

15 thinking about. I’m sorry, but it’s disappointing. 

16 MR. JASINSKI: If we can -- if I can find 

17 that specific language I’ll forward that to Harvey 

18 after the meeting, and if it’s not there, then I 

19 apologize for the misunderstanding. 

20 MR. BROOKMAN: I’m trying to get as much 

21 understanding on the record, you know, sort of in a 

22 coherent fashion here. So what I think I’m 

23 interpreting, Sam’s description using this figure in 

24 PowerPoint slide 19 of the fan being integral or 

25 part of the entire unit, that description I thought 
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1 that that was going to address some of the concerns 

2 we heard earlier. Charlie? 

3 MR. STEPHENS: My interpretation of what 

4 I’ve heard just in the last few minutes is that DOE 

5 is proposing to regulate furnace fans but test air 

6 handlers. If they’re proposing to test air 

7 handlers, I would suggest that the testing of air 

8 handlers is a lot more complicated than what’s in 

9 this diagram. I mean you have to start specifying 

10 what appertances are now in the air stream in the 

11 air handler, among other things, and you start 

12 getting into things like cabinet leakage and all 

13 kinds of other things that DOE has said they don’t 

14 want to deal with. 

15 So I don’t know how you can propose to 

16 regulate a fan and test an air handler. That’s a 

17 little bit beyond me. 

18 MR. BROOKMAN: Okay. Thank you. Do you 

19 have anything else at this point? 

20 MR. JASINSKI: No, just to go back to -- 

21 MR. BROOKMAN: The comment box? 

22 MR. JASINSKI: -- yes, the comment box. 

23 MR. BROOKMAN: To the comment box. Do 

24 that. Because the Department still seeks additional 

25 comment -- Frank Stanonik. 
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1 MR. STANONIK: Frank Stanonik, AHRI, sorry 

2 I was a little late. Following up on Harvey’s 

3 comment, I mean, yeah, it would have been nice to 

4 have this diagram but for some of us that are still 

5 trying to sort out exactly what’s being proposed 

6 here, I would suggest that maybe we need a diagram 

7 of how you would make these measurements on the 

8 furnace. Yeah, this is all well and good, but if 

9 we’re going to something like this on the furnace, 

10 you know, there’s plenty of diagrams already in 

11 ASHRAE 103. I think, you know, DOE, if they’re 

12 going to show a diagram of where these measurements 

13 would be taken and everything else, then we wouldn’t 

14 have to guess about things. 

15 MR. JASINSKI: Just as a quick follow up 

16 maybe to some of the industry participants can help 

17 me out. Is that -- in comments and in subsequent 

18 discussions, DOE learned that a lot of manufacturers 

19 use setups that are very similar to this. So if 

20 there’s a manufacturer that uses a setup that’s very 

21 similar to this, maybe in their written comment or 

22 even in a follow up comment here, maybe they can 

23 provide maybe some specific questions as to what’s 

24 confusing. Because DOE found that manufacturers and 

25 industry participants and in also studies that were 
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1 conducted by industry participants that aren’t 

2 manufacturers, that these are methods that were 

3 being used specifically to test setup. So maybe 

4 someone that has had experience with testing like 

5 this, which DOE did conduct some testing, so this is 

6 the setup that we used and there didn’t seem to be 

7 this type of confusion. We were under the 

8 impression that we were using very similar methods 

9 to what was being used in industry to develop the 

10 performance tables that can be found in a lot of 

11 product literature. Maybe they can explain how what 

12 they’re doing is different than this diagram. 

13 MR. BROOKMAN: Yes, Roy. 

14 MR. ROY: Aniruddh Roy with AHRI. I want 

15 to echo what Jim Vershaw and Greg Wagner said with 

16 respect to the ANSI/AMCA standard 51 -- I’m sorry 

17 the ASHRAE 51 and also the ASHRAE standard 37. It 

18 all comes down again, to the scope, how the scope 

19 has been interpreted over here. With respect to 

20 central air conditioners and heat pumps, there are 

21 federal test procedure does reference ASHRAE 37 and 

22 so the external static pressure measurements by 

23 manufacturers are made using the ASHRAE 37 standard. 

24 Whereas now, just with AFUE and FER, we’re now, for 

25 furnaces, manufacturers will have to use two 
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1 different static pressure measurements, even the 

2 central air conditioner and heat pump manufacturers 

3 will be subject to two different standards and two 

4 different external static pressure measurements. So 

5 we would encourage DOE to look into that a little 

6 further and we will submit comments on the 

7 differences in standard air and the ESPs that are 

8 referenced in 51 as well as ASHRAE 37. 

9 MR. BROOKMAN: Okay. 

10 MR. JASINSKI: As a follow up to that, I’d 

11 also ask that in the written comments, referring to 

12 my earlier request, that you also provide -- it 

13 sounds to me like Jim Vershaw said that there are a 

14 lot of similarities between the actual equipment and 

15 test setups that are used in 37 and 210, and while 

16 Roy brings up good points about their being 

17 differences in how you adjust for standard air and 

18 the external static pressures, if you could also 

19 provide information about how maybe the test setups 

20 in ANSI/AMCA 210 vary from what’s being used as 

21 specified in ASHRAE 37, as it pertains to specific 

22 equipment, placement of the sensors, all those sorts 

23 of things, because it’s important to understand also 

24 that the preliminary analysis that’s in progress is 

25 based upon the proposed test procedure that we have 
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1 here. So if there are differences in the test 

2 setups between ASHRAE 37 and ANSI/AMCA 210, and 

3 those differences might result in differences in the 

4 values of ESP and air flow performance that are 

5 provided in product literature, it’s important for 

6 DOE to understand why those values might be 

7 different. And if they’re not, we also need to know 

8 that they’re not different. And that was really the 

9 driving motivation behind this question, is to 

10 understand whether or not the values of ESP and air 

11 flow performance that are provided in product 

12 literature are different than what would result from 

13 ANSI/AMCA 210. 

14 I think I remember specifically some 

15 comments saying that the actual values that you 

16 measure using the two different test setups would 

17 not be different. 

18 MR. BROOKMAN: Greg. 

19 MR. WAGNER: I will just comment that AMCA 

20 210 again is designed for testing fans. It’s not 

21 for appliances. It does have a different test 

22 methodology. The way that standard air is corrected 

23 for is different than ASHRAE 37, and the output will 

24 be different, so literature will be different than 

25 what you’re looking for. Again, AMCA 210 is a fan 
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1 industry standard for fans, separate from 

2 appliances. 

3 MR. BROOKMAN: Okay. Jim Vershaw wishes 

4 to comment. Jim, please get close to the microphone 

5 on your machine and speak loudly. 

6 MR. VERSHAW: Okay. I’m on a cell phone 

7 and -- 

8 MR. BROOKMAN: It’s coming through. Yes, 

9 that’s better now, just speak loudly. 

10 MR. VERSHAW: Okay. I’m going to 

11 reiterate that 37 is correct. If you look at the 

12 figure that’s on the screen, 37 doesn’t include the 

13 PF7 measurement, that measurement is made closer to 

14 the unit, that’s the way it’s done in 103 for the 

15 test standard for furnaces. That’s the way it’s 

16 done in the ... calculation, and we do not measure 

17 velocity pressures because fundamentally you have ... 

18 but they cancel out so there’s no need for it, and 

19 that’s where the key difference is, as well as the 

20 correction factors on the air. I think we did it 

21 the other day, about half a percent difference in 

22 air flow which ... that up when you start doing 

23 enforcement on this. ... look at, because the 

24 nozzles and everything to the right are all the 

25 same, but it’s the high external static pressure and 
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1 high stressed air flow, high ... unit which is key 

2 here and that’s what we want to be doing the same we 

3 have to be doing for all other regulations. Thank 

4 you. 

5 MR. BROOKMAN: Okay. Thank you. 

6 MR. JASINSKI: Thank you. That was sort 

7 of what I was getting at, is comparing the test 

8 setups, so more comments like that in written 

9 comments would be very much appreciated. 

10 MR. BROOKMAN: Are there any additional 

11 comments that you see there, issue box number 7, 

12 about the ANSI/AMCA 210-07 setups? 

13 MR. JASINSKI: We’re not quite there yet, 

14 even though this conversation -- 

15 MR. BROOKMAN: Sorry, I flashed forward. 

16 MR. JASINSKI: That’s okay. I just didn’t 

17 want to provide more -- 

18 MR. BROOKMAN: We’re talking about issue 8 

19 which is on the previous slide -- 

20 MR. JASINSKI: One more clarification, and 

21 this is related to the second part of the request 

22 for comment, which is to provide feedback on the 

23 actual definition that’s proposed, and just to 

24 provide a clarifying factor. A lot of -- some 

25 clarifying information -- a lot of the comments back 
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1 are referring to negligible velocity pressure, and I 

2 do just want to point out that -- or make sure to 

3 clarify that in DOE’s proposed definition, we’re 

4 also proposing a definition that excludes inlet 

5 velocity pressure, and I sort of provided some 

6 equations here above that describe, theoretically, 

7 how someone -- how one would calculate an external 

8 static pressure drop or static pressure difference. 

9 And then below that I provided equations that 

10 describe how the proposed definition in the NOPR, as 

11 well as the definition in AMCA 210, describe how to 

12 calculate this pressure -- a static pressure 

13 difference. And I’ve highlighted in red the inlet 

14 velocity pressure to show that that’s excluded from 

15 both the proposed NOPR definition and the ANSI/AMCA 

16 210 definition, which, if I’m hearing comments from 

17 interested parties correctly, that’s accurate to 

18 describe how it’s done -- how these measurements are 

19 taken currently, whether it be for ASHRAE 37 or 

20 ANSI/AMCA 210. 

21 MR. BROOKMAN: Let’s just let that slide 

22 sit for a moment. Those equations are not in the 

23 PowerPoint deck. 

24 MR. JASINSKI: Oh, I apologize. 

25 MR. KHAN: There’s been some sort of -- 
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1 Mohammed Khan, DOE. We certainly apologize for the, 

2 I guess, printer error here. I think if you go to 

3 our web page and pull this presentation up, you will 

4 definitely see all the terms to the equations there. 

5 So, as you think about it and develop your written 

6 comments, and want to refer back to this, please go 

7 to the web page and pull it up. Thanks. 

8 MR. BROOKMAN: So now with these equations 

9 here, are there any additional comments before we 

10 move on? Do you have anything else? 

11 MR. JASINSKI: Yes, the ultimate question, 

12 and whether someone wants to comment on this now, or 

13 at least provide it in written comment later, the 

14 ultimate question again is, there are a lot of terms 

15 being thrown around for the static pressure, but 

16 what’s important to the Department of Energy is to 

17 pay attention to the definition that we provide and 

18 what that means for how these measurements were 

19 taken, and we want to make sure that that’s 

20 appropriate, number one, and also if it isn’t 

21 appropriate, why? And if it is appropriate, we also 

22 want to verify that the definition that we’re 

23 proposing, regardless of what we want to call it, is 

24 consistent with how these measurements are -- the 

25 measurements that are published in product 
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1 literature. So those are the two main points. Is 

2 that we can call it something different if you’d 

3 like, but the definition, how DOE is understanding 

4 that these values are calculated and whether those 

5 are consistent with how it’s done in the industry, 

6 those are the important aspects of this comment. 

7 MR. BROOKMAN: Okay. We’re about to move 

8 on. Final comments on issue box 8, on slide 18. 

9 Okay. 

10 MR. JASINSKI: Thanks. And also, I think 

11 there’s a lot of slides that have equations or 

12 things that may have gotten messed up when printing 

13 them, so if that’s the case, just let me know so I 

14 can spend a little bit of extra time explaining them 

15 if you need to, because since you haven’t had time 

16 to look at them previously. 

17 So the next request for comment, which is 

18 closely related to the one we were just discussing, 

19 there was a lot of overlap, is that DOE recognizes 

20 that ANSI/AMCA 210 includes 16 different setup 

21 variations. DOE did not propose a specific 

22 variation in the proposed test procedure. DOE 

23 expects that the blow-through setups, such as the 

24 test setup in figure 12, which was the same figure 

25 that I showed in the previous slide may be more 
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1 appropriate than pull-through setups, like setup 

2 number 13, because the blow-through setup is more 

3 representative of how a typically HVAC installation. 

4 So the request for comment, DOE would like 

5 some feedback on which of the ANSI/AMCA 210 setups 

6 are best suited for the types of testing that we are 

7 proposing, and if there are any that are 

8 inappropriate, whether they should specifically be 

9 excluded from use in the proposed test procedure. 

10 And this might be a good time to identify any that 

11 are as closely related -- are more closely related 

12 to ASHRAE 37 than others. 

13 MR. BROOKMAN: Roy. 

14 MR. ROY: We brought this issue up with 

15 our industry and it looks like as far as blow16 through units are concerned, it might apply to non17 weatherized gas furnaces, but in the case of 

18 weatherized and electric furnaces you do have some 

19 units where there is a pull-through. And so we were 

20 wondering how DOE, or whether DOE can provide some 

21 specific data and justification before any test 

22 setups are eliminated altogether from the final 

23 rule. 

24 MR. JASINSKI: Provide specific data 

25 about? 
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1 MR. ROY: In the sense that -- in this 

2 case it looks like the blow-through is going to be 

3 the preference as far as the setup is concerned. 

4 But you have, obviously, in the industry, units that 

5 also do the pull-through. So how would we test for 

6 those? 

7 MR. JASINSKI: That’s what we’re asking 

8 you. We would like to know if there are specific 

9 setups that are, you know, you say that there are 

10 both blow-through and pull-through. Is there a 

11 specific setup variation in ANSI/AMCA 210 that the 

12 industry prefers, or already uses for blow-through 

13 and a different one for pull-through? And if so, 

14 what are they? And explain why those specific ones 

15 are used. And if there are setups in -- if any of 

16 the 16 setups are inappropriate, we can explicitly 

17 exclude those also. 

18 MR. BROOKMAN: Craig. 

19 MR. MESSMER: Craig Messmer. I think the 

20 confusion is is that you’re referring to something 

21 that you use when you test the fan through AMCA 210. 

22 When you do an air handler or furnace, it’s a unit, 

23 it’s an appliance. Where we put the fan inside of 

24 that box is up to us, depending on what kind of 

25 appliance it is. That determines whether it’s blow-
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1 through or pull-through. Test setup itself doesn’t 

2 really take that into consideration, doesn’t really 

3 care. 

4 MR. JASINSKI: As a follow-on to that, 

5 maybe I should provide more clarification on what we 

6 mean by blow-through and pull-through. In this 

7 particular case, what I’m understanding Craig is 

8 saying is that he’s looking at blow-through and 

9 pull-through in relation to where maybe the fan is 

10 within the product related to the heat exchanger and 

11 other things. When I refer -- when we refer to 

12 blow-through and pull-through here, we’re talking 

13 about whether or not the fan is blowing air through 

14 the duct work and central system, or whether it’s 

15 pulling it through that duct work or the central 

16 system. 

17 MR. BROOKMAN: Craig. 

18 MR. MESSMER: Okay, let me -- most air 

19 handlers do both. They have supply and return duct 

20 system, so it’s hard to distinguish whether you’re 

21 talking about a blow-through and pull-through 

22 system. For sure, the supply side usually has the 

23 higher static pressure, so a pressure drop. So if 

24 that’s your consideration on a blow-through, then 

25 you would be accurate. 
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1 MR. BROOKMAN: Do existing test methods 

2 specify -- do they differentiate between blow3 through and pull-through? 

4 MR. MESSMER: No. 

5 MR. BROOKMAN: They do not. Okay. Yes, 

6 Adam. No? 

7 MR. CHRISTIANSEN: I think AMCA 210 

8 usually just has a ducted inlet or a ducted outlet, 

9 and that’s kind of how they prefer things. So 

10 instead of it being -- I don’t remember their being 

11 a pull-through or a blow-through language. I could 

12 have missed it if -- 

13 MR. JASINSKI: I think there are certain 

14 setups where, I think in this case, the fan would be 

15 -- the setup would be reversed and the air flow 

16 would be reversed. That’s what we mean by the pull17 through. Okay. 

18 MR. BROOKMAN: NO, Craig, talk to us. 

19 Confirmation is useful. 

20 MR. MESSMER: I’m just going to agree with 

21 what you’re saying. I believe you’re talking about 

22 the test setup with the nozzles. 

23 MR. JASINSKI: Yes. 

24 MR. MESSMER: Okay. You’re not talking 

25 about the unit itself, whether you want to test the 
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1 fan on the left side or -- 

2 MR. JASINSKI: Yes. 

3 MR. MESSMER: -- the right side of the air 

4 nozzle chamber.-- the right side of the air nozzle 

5 chamber. 

6 MR. JASINSKI: Yes, thank you. I’m sorry 

7 I wasn’t more clear about that. 

8 MR. MESSMER: That’s what you’re trying to 

9 say -- 

10 MR. JASINSKI: Yes. 

11 MR. MESSMER: -- I would have to agree, 

12 from my experience, what you show on the slide 

13 there, which is in the AMCA 210 standard, that’s 

14 where the drawing comes from, that’s probably the 

15 most common setup. 

16 MR. JASINSKI: Thank you. 

17 MR. BROOKMAN: Okay. 

18 MR. JASINSKI: Any other comments 

19 regarding the test setups? 

20 MR. BROOKMAN: Yes, Roy. 

21 MR. ROY: One clarification that we are 

22 seeking is with respect to the filters. Does DOE 

23 want the testing to be done with or without filters? 

24 MR. JASINSKI: No, filters are included. 

25 MR. BROOKMAN: Jim Vershaw, are you with 
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1 us, Jim? You‘re next. 

2 MR. VERSHAW: Yes, this whole conversation 

3 is really moot in my point. I don’t think any of 

4 the 16 setups are appropriate because they’re not in 

5 ASHRAE 37. If you use ASHRAE 37 this is the issue, 

6 it’s all defined how you setup the unit and how you 

7 run the test. Now, as far as filters go, a lot of 

8 furnaces are not shipped with filters, so what are 

9 you going to use for filters if you have to put the 

10 filters? 

11 MR. JASINSKI: I’ll make a clarification. 

12 The -- 

13 MR. BROOKMAN: Not yet. 

14 MR. JASINSKI: Sorry. 

15 MR. BROOKMAN: Not yet. He’s making a 

16 very broad comment here and I want to see if anyone 

17 has follow on. In fact, Jim, I noticed you were 

18 nodding your head. I don’t want to put you on the 

19 spot, not really. 

20 MR. STANONIK: Frank Stanonik, AHRI. And 

21 again, I’m trying to catch up here and that’s my 

22 difficulty. But also the lines of what Jim Vershaw 

23 was saying, and what Charlie Stephens said, yeah, 

24 I’m trying to -- I’m still trying to relate this to 

25 a furnace, and sitting here thinking I’m trying to 
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1 picture these residential installations that 

2 somewhere in the system I’ve got this fan drawing 

3 all the air through my duct system, and I’m having a 

4 hard time envisioning those, because again, I just 

5 keep taking -- I thought we were talking about a 

6 furnace rule, and most of the furnaces I know, they 

7 come with a fan and blower, and I think it’s pushing 

8 the air through somewhere. 

9 MR. BROOKMAN: So this is a broad 

10 conceptual point. Before we get to Sam’s 

11 clarification, additional comments on that? Yes, 

12 Greg. 

13 MR. WAGNER: Greg Wagner again. Yeah, I 

14 think what Jim Vershaw said, we’re starting from the 

15 wrong standpoint. 210 doesn’t apply to these 

16 appliances. So doesn’t matter what figure you 

17 choose, should just go to a standard that applies to 

18 how you test a furnace. 

19 MR. BROOKMAN: Now, Sam, you were going to 

20 clarify. 

21 MR. JASINSKI: Sure. A couple. So to 

22 Frank’s comment, I think Craig did a better job of 

23 explaining what I meant. I wasn’t referring to 

24 furnaces that pull through air through the entire 

25 system. I was talking about, in relation to the 
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1 setup, whether the fan would be -- whether the 

2 furnace would be to the right or to the left. So, 

3 thank you, Craig, for that. 

4 And then the other clarification I wanted 

5 to make is that, to Roy’s comment, and also Jim 

6 mentioned that the filters being included. I 

7 misspoke when I meant that the test setup included a 

8 filter. I’ll go -- later on in the presentation, 

9 I’ll refer to how filters are incorporated, and 

10 actual physical filters, not necessary in the test 

11 setup, but filters -- the pressure drop across a 

12 filter will be included in the results of the test, 

13 based on where we set the reference system external 

14 static pressure. So the results will reflect 

15 performance as if a filter was present, but it 

16 doesn’t need to be present -- it won’t be present 

17 during the test of the unit. 

18 MR. BROOKMAN: Terry. 

19 MR. SMALL: Terry Small, Mortex. So Sam 

20 you’re saying -- now I’m really confused. You’re 

21 saying that if the product doesn’t normally ship 

22 with a furnace, not to worry, it will be adjusted 

23 for that. 

24 MR. JASINSKI: Filter. 

25 MR. SMALL: If the product ships with a 
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1 filter -- I’m sorry, I meant filter -- then take the 

2 filter out before you test it, because it will be 

3 incorporated later in the calculations. Is that 

4 right? 

5 MR. JASINSKI: Yes. And this might be a 

6 good opportunity to -- 

7 MR. SMALL: And you all will be sure in 

8 the enforcement phase to pull a filter out of there 

9 before you test it? 

10 MR. JASINSKI: If I’m there, I’ll make 

11 sure it’s out. 

12 MR. BROOKMAN: I’d like to make certain 

13 that in this meeting today, to the extent possible, 

14 everybody that’s commenting can say what they think 

15 the Department should do, how they should address 

16 these issues. We’re on that pathway some. I want 

17 to make sure we stay on that path. Additional 

18 comments on this series of issues? Okay. We’re 

19 going to move on. 

20 MR. JASINSKI: The final question, or 

21 request for comment regarding ANSI/AMCA 210 is 

22 related to barometric pressure specifications. DOE 

23 is aware that barometric pressure changes may have 

24 an impact on the test measurements, and DOE notes 

25 that ANSI/AMCA 210 standard does not appear to 
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1 include a correction for this effect. Well, it 

2 might be more appropriate to say that the language 

3 in ANSI/AMCA 210 is not strong enough to indicate 

4 that it’s a requirement to adjust for standard air 

5 and therefore correct for any variations in 

6 barometric pressure. 

7 So DOE requests comment on whether any 

8 limitations on the barometric pressure range, or any 

9 additional adjustments should be specified in 

10 ANSI/AMCA -- in the DOE proposed test procedure. 

11 MR. BROOKMAN: Greg. 

12 MR. WAGNER: AMCA 210 does clearly define 

13 standard air and does have a correction for 

14 barometric pressure. It is not an option. It is a 

15 requirement. 

16 MR. JASINSKI: Okay. In Section 7.9, I 

17 think the language was something that air may be 

18 corrected for something, so there may be is where 

19 we’re taking issue is that the question might be is 

20 it -- if it’s a standard industry practice to 

21 correct for standard air, we want to verify that, 

22 and also in the proposed DOE test procedure, if 

23 that’s an important part of the testing method, 

24 which we suspect it is, we want to make sure that we 

25 explicitly state it, or make that language stronger. 
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1 MR. WAGNER: Okay. It is in the standard 

2 -- it says it shall be -- 

3 MR. JASINSKI: Okay. 

4 MR. WAGNER: -- it’s not arbitrary that 

5 you do that, so it is written in that language. I 

6 have a copy of it here if you want -- 

7 MR. JASINSKI: Now this might be a good 

8 time to raise the question of what and how -- the 

9 impacts of the differences between how -- how you 

10 correct for standard air according to AMCA 210 

11 versus ASHRAE 37, which, you know, if someone would 

12 like to provide an explanation now or just in 

13 written comment, that’s something that sounds like 

14 will be important. 

15 MR. WAGNER: I’ll go again -- Greg Wagner 

16 again. AMCA 210 does a -- it treats the correction 

17 factor as a constant volume machine that you’re 

18 pumping out a constant volume of air, and so it 

19 assumes that if you correct to standard density that 

20 you adjust it as if it’s constant volume. The 

21 ASHRAE 37 corrects it as a constant mass flow 

22 equation, so it adjusts differently, so the two of 

23 them go in opposite directions, and so that may be 

24 why you see some differences between the numbers 

25 you’ve been looking at versus what you see in 
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1 published literature. Neither one of them are 

2 wrong. They’re just differences on how it’s done 

3 from a fan perspective, it should be treated as a 

4 constant volume device. From a stand alone 

5 appliance, it is power limited, it should be treated 

6 as a mass flow device, which is really what you’re 

7 trying to figure out from a heat transfer standpoint 

8 in a furnace, air conditioner, et cetera, you want a 

9 mass flow ... 

10 MR. JASINSKI: Thank you. 

11 MR. BROOKMAN: Thank you. 

12 MR. JASINSKI: Yeah, I’d just like to 

13 point out that that’s a model comment, because 

14 explanations like that really help us in, not only 

15 figuring out the appropriate way to do things, but 

16 also why they’re being done. So comments that are 

17 detailed like that are very appreciated. Thank you, 

18 Greg. Any other comments regarding the barometric 

19 pressure adjustments? 

20 MR. BROOKMAN: And particularly if there 

21 are any comments that have a different perspective. 

22 Nothing additional. Okay. 

23 MR. JASINSKI: Thank you. So moving away 

24 from the active mode reference standard, I’ll speak 

25 a little bit about the standby and off mode test 
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1 procedure. As was mentioned earlier, pursuant to 

2 EPCA, DOE is proposing to establish standby and off 

3 mode electrical energy consumption test methods. In 

4 this test procedure, however, DOE is already 

5 addressing standby and off mode electrical energy 

6 consumption in many products that are included in 

7 the Scope of Applicability. Those products 

8 generally fall into the category of residential 

9 furnaces, and residential CAC. 

10 So this table here provides a brief 

11 summary of DOE’s latest rulemaking activities. 

12 There are a lot more and there’s a similar table in 

13 the actual notice that provides a lot more detail 

14 about the history of the rulemaking activities as 

15 they relate to standby and off mode for residential 

16 furnaces and CAC. However, DOE does not currently 

17 have test procedures or a standard that considers 

18 standby and off mode consumption for hydronic air 

19 handlers, so as a result, DOE is proposing to 

20 establish those methods in this test procedure. 

21 MR. BROOKMAN: Terry. 

22 MR. SMALL: Terry Small, Mortex. And 

23 maybe this was discussed in the framework, but that 

24 was two years ago, but I’m trying to understand. It 

25 seems to me, and correct me if I’m wrong, but the 
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1 standby and off mode was something that DOE was 

2 required to include, but only for those products 

3 that are in the scope that they covered, product 

4 classes. And I’ve yet to find where it says that 

5 hydronic air handlers are in a product class or ever 

6 even mentioned at all. So I guess what I’m trying 

7 to understand -- am I wrong, or is this something 

8 that it’s not a product class but it’s being made 

9 applicable to what we’re talking about today? Maybe 

10 this is an authority thing. I don’t know. 

11 MR. BROOKMAN: Eric Stas. 

12 MR. STAS: Eric Stas, DOE. I mean the 

13 EPCA requirements says that in any final rule for 

14 standards after July 1, 2010, the standards have to 

15 account for standby and off modes. So any product 

16 standards we’re setting after that time -- if we’re 

17 setting a product standard that includes the air 

18 handlers, there has to be standby and off accounted 

19 for. 

20 MR. SMALL: Well, Eric, I’m wondering, 

21 though, I thought that pertained to the product 

22 classes that are being regulated. Or the product 

23 classes that are spelled out in the regulations that 

24 come before. See, hydronic air handlers, I don’t 

25 believe have ever been considered. It’s a different 
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1 beast, I believe, than anything that’s ever been 

2 listed as a product class. 

3 MR. JASINSKI: I’ll just -- 

4 MR. SMALL: Maybe I’m wrong about that. 

5 MR. JASINSKI: No, you’re not wrong. I’ll 

6 just remind everybody that the product classes are 

7 something that are established as part of the Energy 

8 Conservation Standard, which is a separate, but 

9 obviously very related rulemaking, which is being 

10 conducted simultaneously. And the preliminary 

11 analysis which will identify product classes is 

12 something that’s being finalized now. So you’re not 

13 wrong in saying that hydronic air handlers have 

14 never been identified as a product class, but that’s 

15 something that will occur. 

16 So to your question, though, I think is 

17 that hydronic air handlers are an example of 

18 something that meets the Scope of Applicability 

19 criteria that I outlined earlier, and it meets that 

20 criteria, but DOE does not have any current 

21 activities to set energy conservation standards or 

22 establish test procedures for standby and off mode 

23 for those products. So that’s why they’re singled 

24 out here. 

25 MR. STAS: Eric Stas again. The specific 
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1 language of the statute says “any final rule 

2 establishing or advising a standard for a covered 

3 product,” so that doesn’t speak to a specific 

4 product class. So if we have authority to cover 

5 hydronic air handlers as a covered product at all, 

6 then they have to account for the standby. 

7 MR. SMALL: So you all have the authority 

8 to cover the product. It just hasn’t been covered 

9 before. And what I’m hearing is we’re talking about 

10 the test procedure today, which could be applicable 

11 to this type of product, which isn’t covered yet, 

12 but you all have the authority to -- and the Energy 

13 Conservation Standards you’re also working on will 

14 add it to the list, in effect? Or am I just really 

15 confused? 

16 MS. STAS: I think that’s a pretty good 

17 statement. So we’ll look forward to your written 

18 comments. 

19 MR. SMALL: Okay. Thank you. 

20 MR. BROOKMAN: Harvey Sachs. 

21 MR. SACHS: Harvey Sachs, ACEEE. Going 

22 back to slide 8, I think part of our confusion which 

23 will ultimately have to be resolved by the 

24 theologians and lawyers is the first sub bullet 

25 under 42USC dah-dah-dah-dah. Standards for 
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1 electricity used for purposes of circulating air 

2 through ductwork hereinafter referred to as furnace 

3 fans. So the real question underlying Terry’s 

4 concern goes back to whether furnace fan is 

5 shorthand for air handler, which we’ve suggested we 

6 think it is, and certainly not everyone agrees. But 

7 I certainly am getting the impression from Sam as 

8 constructed from his presentation this morning, that 

9 the Department’s interpretation is that furnace fan 

10 equals air handler, including its ... Thank you. 

11 MR. BROOKMAN: Go ahead, Frank. 

12 MR. STANONIK: Frank Stanonik. Just a 

13 quick follow up to that because I was just looking 

14 at the proposed definition of furnace fan, and as I 

15 read that definition, it says “electrically powered 

16 device used in residential central heating, 

17 ventilation and air conditioning systems for the 

18 purpose of circulating air through the ductwork.” 

19 So if I had a device that was only an air 

20 conditioner, only an air conditioner, and the device 

21 that’s moving the air through that product has now 

22 been defined as a furnace fan. 

23 MR. BROOKMAN: That last comment was from 

24 Harvey, and now to Roy. And Jim, you’re next in the 

25 queue after Roy. 
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1 MR. ROY: My name is Roy, AHRI. One thing 

2 we want to point out here is since we are discussing 

3 the various HVAC products that are covered by the 

4 scope of this NOPR, with respect to SEER and HSPF 

5 for air conditioners and heat pumps, they’re already 

6 capturing the electrical consumption of the furnace 

7 fan, or the air handler. So how does DOE propose to 

8 take that into account, given that now the FER 

9 covers those products as well? 

10 MR. JASINSKI: So just as a follow up to 

11 that, I think will apply both to Roy’s question and 

12 a lot of the other comments that we’re receiving, is 

13 to provide a little background on the approach that 

14 DOE took to determine the Scope of Applicability. 

15 The Scope of Applicability in this case is taken 

16 directly from the statutory language. So as 

17 everyone has pointed out, the statutory language is 

18 sufficiently broad to include a lot of products, and 

19 the statutory language sort of translates up -- I’ll 

20 go back to slide 8 -- here. So that broad language 

21 is interpreted by DOE to -- in this resulting Scope 

22 of Applicability. 

23 And the approach for the test procedure, 

24 as Mohammed explained, this is somewhat of a unique 

25 project because it’s never -- it has never been 
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1 regulated by DOE before. In a typical rulemaking 

2 process, you have the luxury of having either an 

3 established -- previously established standard, or a 

4 previously established test procedure in which the 

5 scope of coverage and all these other issues are -- 

6 there’s at least a framework for them. That’s not 

7 the case here. 

8 So the approach for the test procedure was 

9 to come up with a Scope of Applicability that was 

10 sufficiently broad so as to not predetermine which 

11 products would be covered in the energy conservation 

12 standard. So the issue of scope of coverage of the 

13 SEER and other cumulative regulatory burden, and 

14 things of that nature, will be brought up in the 

15 preliminary analysis of the energy conservation 

16 standard. 

17 MR. BROOKMAN: Craig. 

18 MR. MESSMER: Thank you for the slide -- 

19 number 22. You point out modular blowers -- we 

20 don’t make gas furnaces, so I wasn’t paying 

21 attention to that SNOPR last year. What does that 

22 mean, modular blowers? 

23 MR. JASINSKI: Modular blower in this case 

24 is essentially a fan -- in a lot of these products, 

25 such as a gas furnace, or even a central air 
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1 conditioner, within that product there is the 

2 furnace fan or the air that circulates the air 

3 through the ductwork, and then the other components 

4 include heat exchangers, and things of that nature. 

5 A modular blower in this case just refers to a fan 

6 box, essentially, where the component is limited 

7 just to the circulation fan, which is designed to 

8 either stand alone or be paired with the coil -- a 

9 central air conditioner coil only unit. 

10 MR. MESSMER: Craig Messmer again. Does 

11 that mean that it’s not addressed in this rulemaking 

12 at all? 

13 MR. JASINSKI: A modular blower that meets 

14 the criteria of the Scope of Applicability would be 

15 -- this test procedure could be applied to a modular 

16 lower that meets those criteria. 

17 MR. MESSMER: Can you repeat that again? 

18 I’m sorry. 

19 MR. JASINSKI: The short answer is this 

20 test procedure, yes, could be -- you could use this 

21 test procedure to rate the performance of modular 

22 blower. 

23 MR. MESSMER: Okay. So this test 

24 procedure applies to modular blowers? 

25 MR. JASINSKI: Yes. 
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1 MR. MESSMER: Thank you. 

2 MR. BROOKMAN: Terry. 

3 MR. SMALL: Sam, am I hearing -- 

4 MR. BROOKMAN: Just a second. 

5 MR. JASINSKI: I think Eric wanted to -- 

6 MR. STAS: Eric Stas, DOE. I think the 

7 confusion might be here that this is talking 

8 specifically about the standby and off mode. All 

9 these things would be included in the standards, but 

10 the hydronic air handler is the only one that’s 

11 needing a separate piece for the standby. Does that 

12 help? 

13 MR. MESSMER: Yes, it clarifies that, 

14 although I would now make a recommendation that the 

15 standby losses be -- the modular blowers be put 

16 under the same standby loss measurement as the 

17 hydronic air handlers. 

18 MR. BROOKMAN: Okay. Mohammed. 

19 MR. MESSMER: Don’t treat them separately. 

20 MR. KHAN: Mohammed Khan, DOE. Can we go 

21 back to slide 13, Sam, please? 

22 MR. JASINSKI: Sure. 

23 MR. KHAN: And I appreciate your question 

24 and concern, and I understand why there might be -- 

25 well, I understand the basis of the question. And 
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1 on slide 13 at the top here, we indicate heat 

2 capacities of 225,000 and cooling capacities of 

3 65,000, right. And as Sam already described what a 

4 modular air handler is, those seemingly would not 

5 apply. 

6 And then we also talk about a CFM, which 

7 certainly would apply. So to answer your question, 

8 yeah, it’s not just limited to the heating and 

9 cooling capacities, but also the air flow, 

10 volumetric capacity as well. 

11 MR. BROOKMAN: Craig. 

12 MR. MESSMER: Yes, Craig Messmer. Thank 

13 you. I think I’m clarified on the test procedure 

14 for the fan efficiency rating, or whatever that is. 

15 But this is -- to your point, this is about standby 

16 losses? 

17 MR. JASINSKI: Yes, the slide that we were 

18 on, yes. 

19 MR. MESSMER: Okay. It’s being addressed 

20 in a separate rule? I apologize, I’m not familiar 

21 with that separate rule, so I’m just going to make a 

22 recommendation that you just put the modular blowers 

23 inside the same box as hydronic air handlers. I 

24 think it would be better. 

25 MR. BROOKMAN: Okay. Jim Vershaw, thank 
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1 you for being patient. You’re next. 

2 MR. VERSHAW: Okay. Jim Vershaw, 

3 Ingersoll Rand. I’ve got a question about the 

4 definition of a hydronic air handler. I read in the 

5 Federal Register and I’m wondering if a heat pump 

6 air handler that has an accessory that instead of 

7 putting electric heat in, you could put in a 

8 hydronic coil, would then that classify as a 

9 hydronic air handler? Or would it only be a 

10 hydronic air handler when it has the accessory in 

11 it, or would it be a hydronic air handler at all? 

12 MR. JASINSKI: I think I’ll have to look 

13 at the exact definitions in the CFR, but I think 

14 that the hydronic air handler definition describes 

15 it as -- defines it as a furnace, so it includes the 

16 official definition of a furnace. And I believe in 

17 the CFR definition of a furnace, there’s a -- the 

18 operative word is it’s primary function is to 

19 provide heat through various methods, and I think it 

20 lists, you know, electrical furnace, oil, gas. So 

21 in this case, I, you know, this is a proposed rule, 

22 so it’s something to consider, but the intent here 

23 was that a hydronic air handler would be defined as 

24 something where its primary source for heating would 

25 be the hot water source and the hydronic coils. So 
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1 in the case of the hypothetical product -- well, 

2 maybe not hypothetical -- the product that you’re 

3 talking about, a heat pump that has an accessory, 

4 that accessory, I think, would disqualify it as 

5 being the primary source of heat unless maybe the 

6 heat capacity of the hydronic coil or the use of the 

7 hydronic coil was significantly -- designed to be 

8 used significantly more than the heat provided by 

9 the heat pump. 

10 MR. BROOKMAN: Jim, what would you suggest 

11 that the Department do with the product you 

12 described? 

13 MR. VERSHAW: I’m trying to get the 

14 definition in my mind before I come up with a 

15 conclusion on this. 

16 MR. JASINSKI: Well, if you want to 

17 provide a suggested definition in your written 

18 comment, that would be very helpful. 

19 MR. VERSHAW: Yeah, I’m going to reserve 

20 that to the written comments. However, if it is 

21 included, just to beat a dead horse, 37 is the way 

22 to go because we’re already doing all the other 

23 tests under 37, not 51. 

24 MR. BROOKMAN: Thank you. Charlie 

25 Stephens. 
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1 MR. STEPHENS: Charlie Stephens. I’ve 

2 actually specified and overseen the installation of 

3 a number of these products from a few manufacturers, 

4 and to follow up on Jim’s comment. It’s the same 

5 product in many cases that would have a heat pump 

6 coil in it, or would have backup electric strip heat 

7 in it, only in some cases, or a hydronic coil. But 

8 this is a test procedure discussion and I’m 

9 wondering how the Department will specify that that 

10 product be tested, given that they’re proposing to 

11 test an air handler rather than a fan. If you were 

12 testing the fan, it would be fairly simple. Once 

13 you’re testing an air handler, which of those coils 

14 should be in it when it’s tested, or does the 

15 manufacturer have to test it with each of them in 

16 it, separately? 

17 MR. BROOKMAN: Terry. 

18 MR. SMALL: Terry Small, Mortex. Are you 

19 aware, Sam, there’s a product for instance, under 

20 65,000 BTU it would be, I guess considered an air 

21 handler. It would have an A coil, an A water coil. 

22 It would be for a four pipe application where, you 

23 know, in the winter you’re running hot water through 

24 the coil, i.e., a hydronic. And in the summer, 

25 you’re running chilled water through the coil. 
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1 Under 65, maybe in an apartment building. Is that 

2 covered by this? 

3 MR. JASINSKI: That would be considered a 

4 hydronic air handler by meeting the criteria for the 

5 Scope of Applicability, and also the proposed 

6 definition of hydronic air handler. 

7 MR. BROOKMAN: Harvey Sachs. 

8 MR. SACHS: Sam, you may be right, but if 

9 I’m understanding Terry’s description, it might also 

10 be considered commercial product as a terminal unit. 

11 MR. JASINSKI: You’re saying these are 

12 installed in residences or -- 

13 MR. SACHS: It was stated to be -- 

14 MR. SMALL: In multifamily or, you know, 

15 duplexes, quadplexes, I don’t know. 

16 MR. SACHS: But by the time we’re talking 

17 about a chilled water source, it’s a unit that’s 

18 very uncommon in residential applications, and he’s 

19 talking about a four-pipe installation with separate 

20 chilled water and heated water loops, and this -- it 

21 doesn’t sound to me like a widespread residential 

22 product, but it’s your product. 

23 MR. SMALL: It would not be, but it seems 

24 to me that if we’re testing -- if we’ve got some 

25 hydronic air handlers that do not have cooling coils 
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1 in them, but then if we’ve got some hydronic air 

2 handlers that have a circuitry in the coil that is 

3 also for chilled water, those will be highly 

4 penalized for your IFER calculation, because the 

5 other ones don’t really have a cooling coil in place 

6 when they’re tested. 

7 MR. BROOKMAN: I saw Frank Stanonik. 

8 You’re next. Pardon me, for the record, that was 

9 Terry Small just speaking, now Frank. 

10 MR. STANONIK: I just had a -- Terry 

11 raised a very interesting question, and what no one 

12 has said is, so if you will, what is the machine 

13 that’s providing either the hot water or the cold 

14 water -- the cooled water, whatever. I mean, again, 

15 for multifamily installation, and you have whatever 

16 you want to call it, a commercial sized piece of 

17 equipment, boiler or chiller or whatever, that’s 

18 circulating the equipment, then I’m really puzzled 

19 why this rulemaking would address that unit. 

20 MR. BROOKMAN: Terry. 

21 MR. SMALL: Terry again. Sam, aren’t you 

22 really saying when you say 65,000 BTUs, hopefully 

23 you’re talking about the capacity of the overall 

24 system that is pumping the refrigerant or the 

25 chilled water -- I mean this could be -- I mean you 
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1 have a veritable refrigerant flow commercial system, 

2 which the individual cassettes are 12,000 BTUs, but 

3 the unit sitting on the outside is ten tons. So, 

4 maybe the definition needs to drill down into the 

5 fact that the machine that’s actually, you know, 

6 sending the water, sending the refrigerant, 

7 whatever, that that’s what the capacity limitation 

8 is based on. 

9 MR. BROOKMAN: Charlie. Charlie Stephens. 

10 MR. STEPHENS: Yeah, I mean at the very 

11 least you’re going to have to sort this out. I mean 

12 the ones I specify typically, the hydronic air 

13 handlers are -- it’s one coil, hot and chilled water 

14 in the same circuit. It’s a heat pump based system. 

15 But it might be a two roll coil, it might be a four 

16 roll coil. Capacity might range anywhere from 

17 16,000 to 48,000 BTU per hour. And the coil is 

18 different. It fits in a pretty standard product, 

19 variable speed air handler from some of the major 

20 manufacturers that you can put a hydronic coil in or 

21 you can put a refrigerant coil, or you can put 

22 electric strip heat. It’s the same fan, but it’s 

23 got different stuff in the cabinet and I’m just 

24 wondering how many variations of this thing do you 

25 have to test in order to characterize the energy 
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1 efficiency of the thing. 

2 MR. BROOKMAN: Harvey, can you summarize 

3 what the Department should do? 

4 MR. SACHS: I think the most important 

5 thing the Department could do is decide whether it’s 

6 regulating furnace fans or air handlers, and then 

7 test accordingly. Because what I’m hearing here is 

8 kind of a mixture of things, and if you’re going to 

9 test fans, I would use a different -- I would 

10 reference different test methods and I would use 

11 different test procedures than if I was going to 

12 test an air handler. What I’ve seen so far is 

13 incompletely specified. 

14 MR. BROOKMAN: Frank Stanonik. 

15 MR. STANONIK: A couple points. I’m going 

16 to tie into Charlie’s but you had the slide up about 

17 the scope of coverage, and Andrew informs me we had 

18 made a very general statement at the beginning, and 

19 you were citing what the CFR has as far as scope of 

20 coverage. But our reading of the federal law is 

21 that all of these requirements were under the 

22 headings of standards for furnaces and boilers. And 

23 so we’ve got a real -- and we will provide comments 

24 to better delineate this -- but we’ve got a real 

25 concern that what DOE has seen as the scope of their 
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1 coverage is not consistent with the authority that 

2 Congress gave them. And so tying into Charlie’s 

3 comment, I agree, you know, you need to decide what 

4 you’re going to address here and if you are going to 

5 address air handlers, which at this point 

6 necessarily you have the authority to do, but if you 

7 are going to address air handlers, think about it 

8 this way. These other things about hydronic air 

9 handlers, what -- those are all heat exchangers. 

10 Those are basically heat exchangers. So if you’re 

11 going to address the air handler and you’re 

12 interested in what that furnace fan -- what that fan 

13 is doing, then figure out a procedure to simply 

14 measure what the fan, combination fan/motor is doing 

15 and account for the heat exchanges that might be in 

16 the box. But to interject here requirement for 

17 hydronic air handlers or modulars that you’ve never 

18 addressed before in any other rulemakings is, as I 

19 will say, as part of what is significantly 

20 complicating this rulemaking. 

21 MR. BROOKMAN: Thanks, Frank. Craig. 

22 MR. MESSMER: Not to complicate -- this is 

23 Craig Messmer. Not to complicate it further, but 

24 the definition in the publication says hydronic is 

25 for heating air ducts. What about cooling only? 
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1 The water coil? Is that still a hydronic system? 

2 MR. BROOKMAN: Okay. 

3 MR. JASINSKI: As a general follow on, in 

4 terms of how to define hydronic air handlers, my 

5 recollection is that during the framework public 

6 meeting, this was a product that was brought to 

7 DOE’s attention from interested party comments. I 

8 believe it was from Charlie Stephens, actually, and 

9 there was some back and forth about the 

10 commercialization of these types of products and 

11 what the nature of these products were, during that 

12 public meeting. So there is -- in essence, I think 

13 that over the past couple of years they have, I 

14 guess, become more -- more variations have become 

15 commercialized. So it’s important -- and not just 

16 for hydronic air handlers, but especially hydronic 

17 air handlers, because they are somewhat of a new 

18 application, it’s important to provide information 

19 like Terry did, about the different variations that 

20 are available in your written comments if you can 

21 highlight specific models so that DOE can consider 

22 all these variations and their impact on what the 

23 definitions of these products should be, and how 

24 they should be considered in the rulemaking. That 

25 will be very helpful. 
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1 MR. BROOKMAN: Greg, want to comment? 

2 MR. WAGNER: Yeah, I just want to go back 

3 to the scope thing. This is going beyond what was 

4 defined in the law. As the folks at AHRI said, 

5 6295F.4.D clearly defines what this scope is 

6 covering, and it doesn’t cover a lot of the things 

7 on your list here, including the things we’re having 

8 discussions about. And that’s very clearly written 

9 in the law, despite what I heard a lot of ambiguity, 

10 and your representation of what the definition says 

11 in today’s meeting. 

12 MR. BROOKMAN: Thank you. Let’s move on 

13 to the next slide. 

14 MR. JASINSKI: I actually had one more 

15 follow up question, Doug. Frank, you mentioned -- 

16 you sort of provided a little bit of a guideline as 

17 to the different approaches that DOE could take, and 

18 it reflects some of the things that other people are 

19 saying, and I’m just wondering if -- there was some 

20 confusion as to whether we’re just testing the fan, 

21 or we’re testing the entire HVAC product, whether it 

22 be a furnace, hydronic air handler, or whatever. Do 

23 -- it would be good to hear from interested parties 

24 whether they have input as to which one we should be 

25 doing. Should we just be testing the fans 
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1 themselves and providing a rating specifically for 

2 the fan, and not the -- not while it’s installed in 

3 the HVAC product, which is similar, I think, to one 

4 of the approaches you addressed; or the approach 

5 that’s proposed in the Notice of Proposed 

6 Rulemaking, albeit maybe not explicitly enough, that 

7 the unit be tested with the furnace fan integrated 

8 in the HVAC product as it is in the factory. 

9 MR. BROOKMAN: Terry. 

10 MR. SMALL: I think what’s interesting is 

11 that motors, which everybody would know -- nobody 

12 puts a -- plugs in a motor and just lets the motor 

13 spin without a load on it, right. It wouldn’t work, 

14 probably. So motors are definitely a component that 

15 go in a lot of other products, et cetera. Fans, 

16 blower housings, fan wheels, and the motor -- I 

17 think most of us would consider as a component. And 

18 on one hand you’re advocating doing something for a 

19 modular blower, which is really -- I guess that 

20 would be a blower housing, a blower wheel and a 

21 motor, maybe with or without a piece of sheet metal 

22 around it -- that’s kind of almost getting very 

23 close to a component. And then on the other hand, 

24 you’re advocating products that are not even covered 

25 yet -- and they’re all so different. I really 
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1 wonder, and I’m not going to commit myself to it, 

2 but I do wonder if we’re all very interested in the 

3 efficiency of a motor as a component, and that’s 

4 been an important part of the energy efficiency 

5 effort over the years, maybe we should just consider 

6 the fan-blower-motor and, you know, because I mean, 

7 obviously, the motors get applied into products, the 

8 fan assembly and all that can get applied into a 

9 product -- probably make your rulemaking easier. 

10 MR. BROOKMAN: Harvey. 

11 MR. SACHS: Harvey Sachs, ACEEE. The 

12 approach that we’ve recommended in the initial -- in 

13 response to the initial framework document, was to 

14 think about this as the virtual appliance. Our 

15 interest, as an efficiency community, is not in 

16 maximizing the testing burden, but in opening the 

17 paths for the most cost-effective ways to improve 

18 efficiency. One of these, as Terry has noted, is of 

19 course the selection of motor type. We think there 

20 are also opportunities in fans. But clearly the 

21 Department’s own research has shown that another 

22 major effect is simply the impact of the 

23 aerodynamics of the cabinet as it interacts with the 

24 fan. 

25 So it would like to have a system which 
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1 encourages what might be relatively low cost ways to 

2 capture efficiencies there. We recognize that there 

3 are issues in terms of manufacturers desire to be 

4 able to have the air come to that appliance, say a 

5 furnace, from below or either side. We don’t know 

6 that this is an easy engineering problem, but that 

7 was what has influenced our thinking. And from that 

8 thinking, our proposal has been that the Department 

9 consider assigning sort of standard, internal 

10 pressure drops for components that might be size11 dependent, capacity-dependent, but an allowance for 

12 testing with some sort of a default filter that’s 

13 defined, some sort of a default heat exchanger, and 

14 a coil that are defined. With that information, 

15 those who wish to move to higher performance, such 

16 as the ACCA contractors and who wish to utilize the 

17 kind of data that AHRI is committed to releasing, on 

18 BIN performance, for example, will have the tools 

19 and the manufacturers will have the encouragement 

20 for innovation that may lead to capturing some low 

21 cost energy efficiency opportunities. This doesn’t 

22 have to be perfect. It does have to be usable. 

23 And we encourage the Department to think 

24 about things that do provide that balance and do 

25 give us numbers that can be used to reference 
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1 alternative heat exchangers, for example, that have 

2 minimum testing burden and maximum applicability. 

3 We’re not seeing progress in that direction. Thank 

4 you. 

5 MR. JASINSKI: Well, actually I just have 

6 one follow up for that, is that I wonder if any 

7 manufacturers or other industry participants have 

8 any thoughts on the method that Harvey just 

9 presented, which was to, if I’m understanding 

10 correctly, maybe test the fan outside of the HVAC 

11 product but have standardized values for the 

12 external static pressure drops that would be 

13 representative of heat exchangers and other internal 

14 components included in the reference system. 

15 MR. SACHS: Sam -- this is Harvey. Sam, I 

16 believe that you have completely misinterpreted what 

17 I tried to say, and that may have been my fault as 

18 the transmitter. I am extremely interested in the 

19 aerodynamics of the cabinet. I cannot get to that 

20 by testing the fan in vitro, removed from the 

21 cabinet. I’m quite happy to think in terms of 

22 standard pressure drops for the components 

23 downstream which, for example, means you can test it 

24 with those in place or with those removed. But the 

25 goal of those who adopted this in legislative 
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1 language does not seem to me to allow the approach 

2 that you just described. 

3 MR. JASINSKI: Okay. So I’m just trying 

4 to put your approach in maybe practical terms. So 

5 instead, testing the fan while it’s integrated in 

6 the HVAC product, but maybe moving the pressure 

7 sensors so that you don’t capture the actual 

8 pressure drop of internal components, and instead, 

9 add in representative values so that you capture 

10 aerodynamics but also the pressure drop of the heat 

11 exchanger and other internal components? 

12 MR. SACHS: This is Harvey. I may not 

13 have looked at enough furnaces and other air 

14 handlers, but in the six inches between the exit 

15 from the centrifugal fan and the heat exchanger for 

16 the furnace, I don’t know what magic I would have to 

17 use to settle the air enough to make a measurement. 

18 MR. BROOKMAN: Craig. 

19 MR. MESSMER: Harvey, we wish we had six 

20 inches between the blower and the furnace. So from 

21 your lips to manufacturers’ ears. But that’s 

22 another story, for another time. To address the 

23 issue, I guess a little bit of what Harvey’s getting 

24 at, the fan really does need to be part of a system, 

25 and the effect of the system components upon the 
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1 performance of the fan is highly indicative of how 

2 its energy consumption is going to be. And removing 

3 and testing it individually, I don’t know how you 

4 would get a good enough value to determine whether 

5 or not it’s good for any application at all. It 

6 really does need to be part of the appliance. In 

7 fact, you know, later on we’re going to get into how 

8 it’s being tested, but it’s also important to test 

9 it in a way that’s consistent with the way it’s 

10 being applied, and that is tied to its capacity and 

11 not just tied to just some arbitrary CFM or static 

12 point. 

13 Air flow is challenging. Getting good 

14 pressure measurements is extremely difficult, and 

15 all the data that I’ve seen from the field, and I’ll 

16 just say 30-some years of testing fans, I don’t 

17 believe pressure measurements, just as a rule. Just 

18 because they’re notoriously bad and you can’t get 

19 good ones. 

20 So back to, you know, how to test this 

21 thing. Should it be as a system? Should it be --- 

22 I guess I’d liken it to do we want to rate air 

23 conditioners on cars for their efficiency? We can 

24 get the maximum efficiency air conditioner in a car, 

25 but it might weigh 1000 pounds and all of a sudden 
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1 your gas mileage goes from 30 miles a gallon down to 

2 five or ten because you’ve got this huge, giant air 

3 conditioner. I don’t care about that. As an energy 

4 consumer, we want to understand what is the energy 

5 consumption of the entire appliance as it goes in my 

6 house, to heat my house, to cool my house, and not 

7 what individual bits and parts are. And I think 

8 that’s what we need to figure out how we tie that 

9 energy consumption back to what the intended purpose 

10 of this device is so we can get the most energy use 

11 value, if you will, for any given product line, 

12 which is what we’re about here. 

13 MR. BROOKMAN: Mohammed. 

14 MR. KHAN: Mohammed Khan, DOE. I just 

15 want to revisit with Harvey. I certainly understand 

16 what you were trying to explain about potential low 

17 cost opportunities, other methods of approaching 

18 energy conservation, and with the design of the 

19 internal part of the -- the cabinet being made such 

20 that it’s very less -- low restrictive to achieve a 

21 higher energy -- lower energy consumption. But I’m 

22 not so sure exactly how the DOE could actually 

23 regulate such a thing. And let me also mention -- 

24 it wouldn’t really stop there. You could even look 

25 at where the furnace is actually installed, what 
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1 kind of pressure drops are in the HVAC -- the duct 

2 system of the home itself. How could you regulate 

3 that? Or how could you influence that? So I just 

4 don’t know, you know, it is certainly something to 

5 consider, and if we were in a perfect world to 

6 really look at everything under the envelope that 

7 affects the energy consumption. But we’re just not, 

8 and I’m just not sure at this point how it could 

9 even start the regulation of the efficiency of the 

10 restriction of these air cabinets. 

11 MR. SACHS: Harvey Sachs, ACEEE. And I 

12 appreciate what you’re saying, Mohammed. To some 

13 extent I have the luxury of living in a more 

14 idealized world, and I recognize that reducing some 

15 of my dreams to practice can be challenging. We 

16 certainly recognize that the Department’s authority 

17 is limited to the box. I may be the only person in 

18 this room who’s return plenum, at the furnace, 

19 includes turning vanes. Our community has been 

20 concerned about the rest of the system, and in 

21 parallel with this process here, we’ve been heavily 

22 involved in a range of other processes from the -- 

23 ranging from the ACCA quality installation protocol 

24 to looking carefully at things like leakage from the 

25 cabinet and looking at the air leakage requirements 
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1 for new duct systems under Title 24 in California. 

2 We only ask that DOE regulate what DOE has 

3 the authority to regulate. We are in that, working 

4 with the assumption that we know it’s wrong, that 

5 we’re getting an essentially laminar flow coming 

6 into -- from that return plenum to the unit. But we 

7 also know that from that turbulent flow that we’re 

8 getting right behind that, at best, L-bend, we still 

9 have the opportunities for much more efficient and 

10 much quieter operation if we can influence how that 

11 air is entering the circulating fan. We believe 

12 this has significant energy impact. This has been 

13 shown by research at National Lab you all have 

14 funded. And that the air handler regulation should 

15 do its best to unleash the inventive capabilities of 

16 the industry to capture those consumer benefits and 

17 national energy savings. 

18 MR. BROOKMAN: Jim Vershaw, you’re next in 

19 the queue. 

20 MR. VERSHAW: Okay. Jim Vershaw, 

21 Ingersoll Rand. First a couple comments. First one 

22 is you’ve got to test the appliance. You cannot 

23 test the blower out by the appliance. If you go 

24 back to the 1900’s and I was working on fans, I had 

25 a great fan system that worked great on a 51 tunnel, 
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1 but when I put it in the unit, it didn’t work any 

2 better than the one that was already in there. 

3 You’ve really go to work on the appliance, that’s 

4 what you’re working with here. That’s what you’re 

5 dealing with. 

6 In terms of energy efficiency and the 

7 industry, I guess I’m going to take a little bit of 

8 offense to Harvey. If you look at the products that 

9 are available at the companies, you’re looking at 

10 SEER levels in the 20s. You’re looking at AFUEs in 

11 the high 90s, pushing 96, 97, 98. You’re seeing 

12 these motors more and more out there -- we have to 

13 deal with what the homeowner builders associations 

14 are putting out there, some of the ductwork, and I’m 

15 sorry that we can’t do anything in that area, but 

16 the equipment we’re putting out is there. It’s for 

17 homebuilders and other people to see that it works, 

18 and I think we really need to put that focus on what 

19 are we trying to do with this energy descriptive 

20 we’re trying to create here, and what is it going to 

21 do to help people buy equipment smartly. If we’ve 

22 already got a SEER and the furnace is tied in with a 

23 SEER and why are we measuring the air flow and 

24 coolant? I’m at a loss in this whole thing in that 

25 respect, so I think as we get farther into this, 
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1 I’ll have some more comments in that area. Thanks. 

2 MR. BROOKMAN: Okay. Thank you. Harvey’s 

3 next. 

4 MR. SACHS: Harvey Sachs. Thanks, Jim, 

5 and just a clarification, or an apology for my life, 

6 I guess. We certainly have enormous respect for the 

7 innovations that the industry has made in really, 

8 really impressed with all of the progress. And you 

9 could complain that we’re sort of walking around the 

10 edges of field looking if there’s any more grain to 

11 be plucked up, going back to biblical times. But I 

12 think that there is another element here, that there 

13 is a significant fraction of people that are abusing 

14 your equipment by using it in continuous circulation 

15 mode. There are very substantial differences that I 

16 believe industry people have suggested are about a 

17 half a SEER point between a typical PSC application 

18 and typical permanent mag application. 

19 So we think it’s legitimate for the 

20 Department to be thinking about this, but we 

21 certainly want to make it a reasonable thing, that 

22 maybe I could say it this way, gets 85 percent of 

23 the potential benefits with much less than half of 

24 the frightening test burden that might be envisioned 

25 by some. 
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1 MR. BROOKMAN: We’re pretty much due for a 

2 break. I want to finish off one more issue before 

3 we go to break, so Sam, let’s do this one next. 

4 MR. JASINSKI: Sure. So just a recap 

5 before the back and forth, we were discussing 

6 establishing standby and off mode test procedures 

7 for hydronic air handlers or, you know, in the 

8 future just any product for which those modes are 

9 not already being addressed in other DOE rulemaking 

10 activities. 

11 DOE finds that the electrical systems, 

12 i.e., components and controls of hydronic air 

13 handlers are similar to those found in furnaces, 

14 therefore DOE is proposing to incorporate and adopt 

15 the method specified in the DOE test procedure for 

16 residential furnaces and boilers to measure the 

17 standby and off mode electrical consumption of 

18 hydronic air handlers. And there’s a CFR reference 

19 there so you can find the specific provision I’m 

20 talking about. 

21 So DOE seeks comment on whether the 

22 assumption that the electrical systems are similar, 

23 whether that’s an appropriate assumption, and 

24 depending on the feedback we get on that, if they 

25 are similar, is it appropriate to use the DOE 
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1 standby and off mode test procedure for residential 

2 furnaces to measure the electrical performance in 

3 those modes for hydronic air handlers or any other 

4 furnace fan that might not be addressed in other 

5 rulemakings? 

6 MR. BROOKMAN: Charlie Stephens. 

7 MR. STEPHENS: Charlie Stephens. Based on 

8 our field data, I would suggest that I don’t see 

9 anything inappropriate in using the same 

10 methodologies. 

11 MR. BROOKMAN: Roy? 

12 MR. ROY: One comment we have with respect 

13 with the IFER metric that has been proposed in this 

14 NOPR is that hydronic air handlers could be viable, 

15 I guess, replacements for furnaces. And so in the 

16 case of furnaces, now you have standby and off mode 

17 levels that are specified different, and then an FER 

18 level that is representing the furnace fan 

19 efficiency. So what we would recommend is to 

20 decouple the IFER metric for hydronic air handlers 

21 and have those standby and off mode represented 

22 separately so that they can be a similar comparison 

23 done across the products. 

24 MR. BROOKMAN: Dave, you want to comment? 

25 MR. WITTINGHAM: Yeah, I would agree with 
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1 -- this is Dave from Allied Air -- I would agree 

2 with that comment. I think ultimately if you have 

3 products that have similar functions with some 

4 include off cycle power, some don’t, some have 

5 separate off cycle power descriptors that ultimately 

6 that could lead to a confusion to the consumer. 

7 MR. BROOKMAN: Okay. Yes, Craig. 

8 MR. MESSMER: Craig Messmer. I want to 

9 agree with the -- Aniruddh’s comment. We need to 

10 have one FER, not two, for everything -- standby 

11 losses, make them separate, just like they are with 

12 fans. 

13 MR. BROOKMAN: Okay. Additional comments? 

14 Let’s take a break -- Harvey, go ahead. 

15 MR. SACHS: Just one final note on the 

16 consumer as decision maker. And I go back to 

17 comments from industry and a decade ago, about how 

18 consumers use even information like SEER. And what 

19 we’re seeing -- what we hope to see and think we’re 

20 beginning to see, is the ability of contractors to 

21 use DOE information for upselling, for establishing 

22 the value of premium products for their customers. 

23 And this doesn’t have to be a perfect descriptor, 

24 but it ought to be good relative descriptor, and 

25 we’re not convinced that the descriptor suggested by 
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1 AHRI is the right one. We think a number will 

2 matter and will help in the dominant replacement 

3 market -- the market of more right now, I believe, 

4 will help establish the value of the premium 

5 product. And both save energy and improve 

6 profitability for everybody, and it’s changed, so I 

7 hope we can keep that in mind as part of this. 

8 MR. BROOKMAN: Okay. Let’s take a break. 

9 Don’t go anywhere quite this moment. It’s now 

10 11:15, we’re going to resume at 11:30. It appears 

11 as though we’re kind of halfway through the content, 

12 so maybe we will work -- we’ll just see how it 

13 shakes out in terms of the content and how quickly 

14 we move, but as opposed to taking a break for lunch. 

15 In addition, Brenda Edwards requests the 

16 following individuals supply a business card as you 

17 head out for the break, and that would be Gary 

18 Wagner, Dave Wittingham, Terry Small, Craig Messmer, 

19 and Rachelle Cocks, if you can get a business card 

20 to her and then she can get a copy of everything. 

21 You know, there are restrooms on both ends 

22 of the hall. There’s a coffee shop on the ground 

23 floor just directly below us on the opposite side of 

24 the hall. You must wear this badge while you’re 

25 walking around in the Forrestal Building. We’ll see 
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1 you back here at 11:30. 

2 (Whereupon, at 11:15 a.m., the meeting was 

3 recessed for a 22 minute period.) 

4 MR. BROOKMAN: Now that we’re going to 

5 return to talking on the record. So we’ve had a 

6 very productive morning. We’ve covered a lot of 

7 ground, and we’re going to proceed where we left off 

8 which is with Sam and we are on 25, correct? 

9 MR. JASINSKI: Yes. 

10 MR. BROOKMAN: Okay. Let’s resume. 

11 Fan Efficiency Rating, Methodology and Calculations 

12 MR. JASINSKI: So I‘ll pick back up where 

13 we left off by providing an overview of the 

14 methodologies and the calculations used for the 

15 proposed rating metric, which is the Fan Efficiency 

16 Rating, or FER for short. 

17 Just a general description. FER is the 

18 estimated annual electrical energy consumption 

19 normalized by two factors, one, the annual rated 

20 operating hours, and two, the air flow in the 

21 maximum air flow control setting in standard cubic 

22 feet per minute. An operative word in the first 

23 normalization factor is “rated.” It’s important to 

24 note that the annual rated operating hours will vary 

25 depending on the product, mainly on whether or not 
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1 the standby and off mode operating hours are 

2 considered. But I’ll point that out again in the 

3 future. 

4 The estimated annual electrical energy 

5 consumption is a weighted average of fan input power 

6 measured separately in multiple air flow control 

7 settings at different external static pressures. 

8 So the three important components of the 

9 estimated electrical energy consumption are: 

10  The air flow control settings proposed to be 

11 rated, and those correspond to operation in 

12 cooling mode, heating mode, and constant 

13 circulation mode. Many of you are probably 

14 familiar with constant circulation, but for 

15 those that aren’t, constant circulation here 

16 means the mode in which the delivered air is 

17 not necessarily conditioned, but it’s more for 

18 the purpose of providing ventilation. No? 

19 Well, we can get -- 

20 MR. SACHS: Harvey Sachs, ACEEE. In my 

21 experience there are very few residential air 

22 handling systems that have outdoor air coming in to 

23 provide ventilation, and consequently I’m forced to 

24 infer that the circulation mode is predominantly 
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1 about air filtration. It may be a lot of 

2 involuntary infiltration that results from it, but 

3 it’s not the design characteristic. 

4 MR. JASINSKI: Okay. Thank you. 

5 Ventilation and filtration, then. 

6  So the second factor is the power and air flow 

7 measurements are taken at ESPs that are 

8 determined by a reference system that is meant 

9 to represent national average ductwork 

10 characteristics. 

11  And lastly, the input power is weighted by 

12 estimated national average operating hours for 

13 each rated air flow control setting which 

14 correspond to the three modes that I mentioned 

15 previously. 

16 In the subsequent slides, I’ll go into a 

17 lot more detail about each of these aspects of the 

18 rating metric. 

19 Starting with the rated air flow control 

20 settings. Doe is aware that furnace fans typically 

21 have multiple air flow control settings, anywhere 

22 from two up to five and in some high efficiency 

23 units, air flow can be modulated. DOE expects that 

24 each air flow control setting is typically 
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1 designated to perform a specific function, which are 

2 the functions which I mentioned earlier - constant 

3 circulation, heating and cooling -- and that these 

4 designations typically follow the following rules in 

5 that the lowest settings are typically designated 

6 for constant circulation; the median settings are 

7 typically designated for heating operation; and the 

8 highest settings are typically designated for 

9 cooling. 

10 So DOE investigated, knowing that there 

11 can be more than three air flow control settings, 

12 DOE investigated whether or not -- or the 

13 appropriate number of rated air flow control 

14 settings, and determined that rating furnace fans 

15 using three air flow control settings is adequate to 

16 capture efficiency improvements while hopefully 

17 minimizing burden to manufacturers. And this table 

18 here provides a summary of the proposed rating air 

19 flow control settings, depending on different 

20 product types. So a product that is designed for 

21 single stage heating, the lowest proposed rated 

22 setting would be the default constant circulation 

23 setting. The second proposed rating air flow 

24 control setting would be the default heat. And then 

25 the final one would be the maximum, which I have in 
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1 here in parentheses, like we said, is expected to be 

2 typically designated for cooling. 

3 For a multi stage or modulating heat, the 

4 proposed air flow control settings are essentially 

5 the same except for the median proposed rated 

6 setting, which is typically designated for heating, 

7 DOE is proposing to specify that the rated air flow 

8 control setting be the default low heat setting. 

9 And finally for heating only products, 

10 these are products that are not designed to be 

11 paired with any type of cooling, so they’re meant to 

12 be implemented in systems that provide heat only. 

13 Their rated air control settings would be the 

14 default constant circulation, there would be no 

15 median rated air control setting, and DOE expects 

16 that the maximum would be designated for heating. 

17 So for heating only product, there would only be two 

18 rated air flow control settings. 

19 And as a clarification, default air flow 

20 control setting here is meant to be an air flow 

21 control setting that can be achieved in a factory22 set control configuration, i.e., no manual tampering 

23 with the control setting other than through an 

24 interface like a thermostat. 

25 MR. BROOKMAN: Let’s take a few comments 
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1 here. Craig. 

2 MR. MESSMER: Are we missing the cooling 

3 only? 

4 MR. JASINSKI: Cooling only? 

5 MR. MESSMER: We talked about chilled 

6 water, hydronic fan furnaces -- just to mix up a few 

7 terms. 

8 MR. JASINSKI: So it sounds like you’re 

9 suggesting that there are products that are cooling 

10 only, so -- 

11 MR. MESSMER: There are. 

12 MR. JASINSKI: What -- 

13 MR. MESSMER: There absolutely are. Maybe 

14 not in huge numbers, but we sell them. So we need 

15 to know what to do with them. And we also have our 

16 fan controls are easily adjustable in the field by 

17 the contractor. We don’t really -- we have a 

18 default, but it’s not based on anything, so what do 

19 we base it on? 

20 MR. BROOKMAN: So you, the manufacturer, 

21 does not specify a default? 

22 MR. MESSMER: Not for a hydronic fan 

23 furnace. 

24 MR. BROOKMAN: Okay. Charlie Stephens. 

25 MR. STEPHENS: I would agree, we see quite 
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1 a lot of hydronic floor heating systems with cooling 

2 only systems that are not -- there’s no default in 

3 these things. It depends on the cooling load, and 

4 you basically take the product and you do like you 

5 would with anything else, you get the right coil and 

6 the right fan speed, and then you get the right 

7 amount of cooling. So, they’re going in quite a lot 

8 -- that’s how you have cooling with hydronic 

9 heating. 

10 MR. BROOKMAN: Does this structure that 

11 the table that proposes a lowest rating, medium 

12 rated, and highest rated, does this make sense to do 

13 it this way? Should they do it another way? Go 

14 ahead, Craig, and I’m coming back to you, Harvey. 

15 MR. MESSMER: Well, I hadn’t really 

16 thought about it a whole lot, and I’ll make some 

17 comments on it since you asked. But, it may be more 

18 appropriate to put it in terms of BTU requirements 

19 for hydronic systems, rather than air flow 

20 requirements. For example, the small box systems we 

21 operate regularly at much higher static pressures, 

22 so that’s not a really good way to compare our 

23 system to a more conventionally ducted system. More 

24 appropriate way would be based on the BTU content of 

25 that system. Because if you look at it in that way, 
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1 our watts per BTU differences is not much different 

2 for the fan than it would be if you compared watts 

3 per CFM. So, perhaps BTU for hydronic systems would 

4 be a better way to do it. 

5 I’m sure the gas furnaces would have the 

6 same similar issue. They have delta T’s across 

7 their heat exchangers so that really sets the sir 

8 flows more than anything. So I don’t know if I have 

9 an answer for you on this, but calling it maximum, 

10 calling it default, I think is going to be 

11 problematic for the industry to figure out what that 

12 is. 

13 MR. BROOKMAN: You can imagine that DOE 

14 was hoping to create -- let me just speak here -- 

15 trying to create something that was kind of a sort 

16 of a universal character, something that would have 

17 -- applicable and not differentiated unit by unit. 

18 So you can imagine what they’re trying to do here. 

19 Harvey. 

20 MR. SACHS: Harvey Sachs, ACEEE. And I 

21 guess what concerns me, and it’s in the context of 

22 Craig’s comments and your comment just now, Doug, 

23 about universality. Is that over a decade ago, or 

24 about a decade ago, we started to worry about 

25 unintended consequences for niche products such as 
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1 small diameter, high velocity air conditioners. And 

2 the industry went through the process of developing 

3 an anti-loophole specification, and I think the test 

4 method is complete now as well, and adopted, for 

5 these products. They don’t fit under this goal of 

6 the universal thing. And my concern is that this 

7 prior activity doesn’t seem to have been 

8 acknowledged and the reasons for it don’t seem to 

9 have been acknowledged in this effort to get this 

10 universal air handler test method. It may well be 

11 that for some products that are true niche products, 

12 that aren’t going to take over the industry, that we 

13 have to make special accommodations so they can meet 

14 needs. The bed of Precustes (ph) doesn’t work. 

15 MR. BROOKMAN: Craig. 

16 MR. MESSMER: Craig Messmer. To follow up 

17 with Harvey’s -- we do have a separate test 

18 procedure for air conditioners and heat pumps. It 

19 would certainly be needed for fan furnaces as well. 

20 Higher static pressures, lower air volumes, whatever 

21 other characteristics we have. The difficulty, is 

22 how do you compare this type of product to something 

23 else, and that’s really the -- what I’m driving at 

24 with the watts for the fans associated with the fan 

25 based on per BTU or KW output of the heater or the 
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1 cooling system, as opposed to watts per CFM, which 

2 would give us -- make it look worse for us when in 

3 fact, it is not. 

4 MR. BROOKMAN: Greg. 

5 MR. WAGNER: This gets to the question of 

6 some of the earlier suggestions by AHRI and others 

7 in the industry of tying the electrical consumption 

8 to the performance of the product itself. Because 

9 at the end of the day it does have to deliver a 

10 given amount of heating for a furnace-type product, 

11 and that’s what this is about. Not CFM or some of 

12 these other derived, if you will. And so there was 

13 the proposal put forth to tie that together to avoid 

14 these kind of definitions and allow you to dovetail 

15 with what’s already being done in terms of testing 

16 and evaluation of these products, and to use a 

17 similar standard that’s already recognized by the 

18 DOE and others, and to then create an additional 

19 mechanism to evaluate the efficiency of performance 

20 of the fan system within that framework, rather than 

21 going and do some artificial kind of designation of 

22 trying to figure out what the CFM for a given unit 

23 is, which at the end of the day, people don’t buy 

24 furnaces that are rated for CFM, they buy it for the 

25 heating capacity. 
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1 MR. BROOKMAN: Dave. 

2 MR. WITTINGHAM: Just a question for 

3 clarification. I thought I understood you to say 

4 that the product would be tested as it was factory 

5 wired, and the controls -- there wouldn’t be any 

6 field altering of those. And, you know, with our -- 

7 this outline for a typical gas furnace probably fits 

8 for most of those, but even if this is deemed to 

9 extend for air handlers or heat pump type products, 

10 there are variations that will only have one factory 

11 speed, and there may even be heating products that 

12 have only one factory speed. And there’s probably 

13 ways that this calculation could be modified to 

14 allow for that. But those are in the market today 

15 and are in existence, and most heat pumps and 

16 heating and cooling in their primary operation will 

17 use the same speed for heating and cooling. And in 

18 a lot of instances those controls in those systems 

19 don’t have a constant air circulation that’s 

20 separate from the heating or cooling speed. 

21 MR. BROOKMAN: Craig, you got some more? 

22 MR. MESSMER: Well, in conversation with 

23 other manufacturers, for gas furnaces, sometimes the 

24 cooling air flows are lower because if it’s in a 

25 northern climate, they may use a very small heat 
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1 exchanger there. I think in my perspective, we’re 

2 kind of losing the point of energy for the house. 

3 Every house is uniquely different, the ductwork, the 

4 air handlers, the gas furnaces, and what I would 

5 think the Department would want is a tool for 

6 someone to just add them up, rather than try to have 

7 an efficiency rating that’s based on some sort of 

8 average. Because, you know, in my house I may have 

9 one actual energy use, and that’s really what’s 

10 important to me, not really interested in rating. 

11 That way we could compare different, wildly 

12 different types of systems. Basically, add up all 

13 the fan watts plus the SEER watts, plus the EB and 

14 other energy metrics, add it up for each house. I 

15 have one. 

16 MR. BROOKMAN: Charlie. 

17 MR. STEPHENS: Charlie Stephens. We’ve 

18 got a bunch of data we’ll provide to the Department 

19 on air handler energy use, external static pressure, 

20 and all the other metrics we want to know about air 

21 flows, by make and model of the equipment, and 

22 serial number if we really want to get into that far 

23 along, along with all the demographics and the house 

24 characteristics, including the heating loads and 

25 everything else. So -- but what we found, I can 
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1 tell you, because I’ve looked at some of the 

2 preliminary data -- and we’ve got about six months 

3 of data so far -- is that there is a marked 

4 difference in the electrical efficiency of 

5 delivering BTUs to all of these houses. You can get 

6 the right number of BTUs to these houses, two 80,000 

7 BTU per hour furnaces, very nearly identical loads 

8 and external statics and yet one of them is a lot 

9 more efficient electrically than the other, you 

10 know, and I find the difference in the model number. 

11 And it’s in the air handler, and, you know, same 

12 furnace section, different air handler. 

13 So we are interested in that. We are 

14 interested in delivering those BTUs with as little 

15 electrical energy as we can. You know, I’m helping 

16 people plan. I’m helping 130-some utilities plan 

17 for the electrical loads in four states. We are 

18 interested in the electrical loads. So I want to 

19 know how we do this most efficiently, so I am 

20 interested in the individual metrics. 

21 MR. BROOKMAN: Jim Vershaw has his hand 

22 raised. Jim, you’re next. 

23 MR. VERSHAW: Okay. Jim Vershaw, 

24 Ingersoll Rand. A lot of issues where. By bringing 

25 in cooling, it really comes down to this issue 
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1 because, you know, there are multiple tonnages you 

2 can hook up to a furnace, so if somebody’s going to 

3 buy a furnace that’s rated up to three tons, and is 

4 only going to put on two and a half ton, they’re not 

5 going to use the same speed cap or cooling air as 

6 they are for the three ton. So the numbers they’re 

7 looking at a furnace are not correct for their 

8 application. 

9 A lot of the more efficient, newer 

10 furnaces with current magnet motors have maximum air 

11 flow on heating and not cooling. On a modulating 

12 furnace when you’re running at that 35 or 40 percent 

13 of full load and you’re going to use only lowest 

14 detap settings for the calculation, I’m wondering if 

15 there’s some gamesmanship you could do where you’d 

16 only run -- that you run their -- it seems like 

17 there’s opportunity to game the system by doing 

18 that. This is so broad, trying to do so much, we’re 

19 really talking about furnace fan efficiency. It 

20 ought to be focused on the operation of the furnace 

21 fan and how it deals in heating. 

22 MR. BROOKMAN: Thank you. 

23 MR. JASINSKI: Just as a point of 

24 clarification. There’s some questions going around 

25 and in these comments about exactly how these 
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1 specifications would be practically -- would be 

2 applied. And so we -- I don’t think I can put it 

3 any better than how Doug framed it as trying to 

4 apply a universal set of specifications to account 

5 for these variations. In the Notice, for instance, 

6 this says default constant circulation. As I 

7 mentioned before, DOE expects that that’s typically 

8 the lowest air flow control setting. If it’s not, 

9 or if a unit doesn’t have a default constant 

10 circulation setting, in the Notice it specifies that 

11 instead, the lowest air flow control setting would 

12 be used. 

13 And conversely, on the other side of the 

14 spectrum, we’re not -- DOE is not proposing to 

15 specify the default cooling setting, but the maximum 

16 setting. So in instances where a furnace is 

17 designed to be paired with a range of different air 

18 conditioning capacities, anywhere from one ton to 

19 five tons, for instance, the maximum air flow 

20 control setting which DOE would expect to be tied to 

21 the five ton setting would be one of the rated air 

22 flow control settings. So, this framework is 

23 intended to prevent gamesmanship, to use Jim 

24 Vershaw’s terminology, so that it’s not the default 

25 cooling, it’s always the maximum. And in the case 
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1 where the default constant circulation is not the 

2 lowest that would be used, or it’s not specified, it 

3 would be the lowest. So essentially, in most cases, 

4 you’ll have the maximum speed air flow control 

5 setting, the lowest air flow control setting, and 

6 whatever the default heat or low heat setting is for 

7 multi-stage or modulating heat. So in cases where 

8 maybe the default constant circulation and the heat 

9 -- default heat setting are the same, then you would 

10 be rating in that one air flow control setting for 

11 that model. 

12 Any other comments or questions? I hope 

13 that clarified it a little bit. Okay, so moving on 

14 to provide a little bit of context to the air flow 

15 control settings, this figure shows air flow and 

16 power consumption across a range of external static 

17 pressures for the different air flow control 

18 settings in a non-weatherized, non-condensing gas 

19 furnace that uses a four speed PSC motor. The solid 

20 curves at the top represent air flow versus external 

21 static pressure, and correspond to the primary Y 

22 axis on the left, and the dotted curves, at the 

23 bottom of the figure are input power consumption, 

24 and those correspond to the secondary Y axis on the 

25 right. 
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1 You’ll notice that for this particular 

2 model there are four available air flow control 

3 settings. Based on the proposed specifications, the 

4 three that are in color would be selected. And if 

5 you see in the legend, based on the information 

6 that’s provided in the product literature, the 

7 maximum air flow control setting is designated for 

8 cooling; the default heat air flow is the medium low 

9 setting there in red; and the default constant 

10 circulation air flow is in green, and that 

11 corresponds to the lowest air flow control setting. 

12 So this is an example of an actual model that meets 

13 the -- that validates the assumptions provided for 

14 the designation of air flow control settings to map 

15 to specific functions. 

16 Another thing to note here is that you can 

17 see that the air flow and the electrical consumption 

18 -- I’m sorry. 

19 MR. SACHS: Excuse me please. Harvey 

20 Sachs. The family of dotted curves is different 

21 from the family of solid curves, and what was the 

22 difference? That went by me too quickly. 

23 MR. JASINSKI: The top curves are air 

24 flow, so that’s a measurement of CFM versus external 

25 static pressure -- 
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1 MR. BROOKMAN: The left axis. 

2 MR. JASINSKI: Yes. And then the ones on 

3 the bottom are input electrical power. 

4 MR. BROOKMAN: On the right axis. 

5 MR. JASINSKI: Right. 

6 MR. SACHS: Thank you. 

7 MR. JASINSKI: Sure. And another point to 

8 take note of is that the colors correspond, and you 

9 can see that electrical power consumption reduces as 

10 you use lower air flow control settings. And DOE 

11 finds, in comparing data across a lot of different 

12 model, the same data, that the range of available 

13 air flow control settings or the difference between 

14 the highest and the lowest varies greatly, and also 

15 the magnitude of the reduction in electrical energy 

16 consumption as you move to lower air flow control 

17 settings is -- can be drastically different 

18 depending on the types of technology that are used. 

19 So those are important factors in DOE’s 

20 decision to propose a rating metric that’s based on 

21 multiple air flow control settings as opposed to a 

22 single air flow control setting, which is typically 

23 specifying measurements in a single air flow control 

24 setting are characteristic of a lot of the proposed 

25 metrics that were mentioned in the opening 
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1 statements, like E-sub-b and also indicative of the 

2 methods that are proposed in some of the alternative 

3 reference standards that were mentioned, like AMCA 

4 210-240. 

5 So at this time DOE would like to request 

6 comment on the appropriateness of the proposed 

7 rating metric methodology, and the assumptions 

8 related to how air flow control settings are 

9 designated to provide specific functions, and then 

10 also how these designations are made for multi-stage 

11 products, or modulating products. 

12 MR. BROOKMAN: Harvey Sachs. 

13 MR. SACHS: Harvey Sachs, ACEEE. I think 

14 this is really a question for Eric and Mohammed, but 

15 I’m seeing the requirement for multiple air flow and 

16 power measurements and it seems to me the only way 

17 you can go. The question is, what will be 

18 certified? Each of those measurements, or the 

19 calculated FER? Because there’s a very great 

20 difference in terms of the burden -- measurement 

21 burden for the manufacturers, depending on which way 

22 that’s done. I think it has to be the single FER 

23 ‘cause otherwise you’re going down the multiple 

24 metrics path, much as I -- well, I’ll stop there. 

25 MR. KHAN: This is Mohammed Khan, DOE. As 
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1 Sam was describing, there is obviously a benefit and 

2 need to take the different values, but to come up 

3 with a value for regulation, all of that would be 

4 factored in. So would it be an average or just the 

5 FER, I think that’s still open to consideration. 

6 MR. SACHS: Okay, so the -- the assumption 

7 is that a manufacturer would not be in jeopardy of 

8 delisting or regulatory action if one of these 

9 values were in error, as long as there were 

10 compensating errors so the FER calculated was within 

11 your tolerance ... 

12 MR. KHAN: Mohammed Khan, DOE. That would 

13 seem to make very good sense. 

14 MR. SACHS: Thank you. 

15 MR. BROOKMAN: So you see the comment box. 

16 Let’s see if we can get some specifics with respect 

17 to what’s listed as issue one. Greg, it looks like 

18 you’re almost ready. Roy, go ahead. 

19 MR. ROY: Aniruddh Roy, AHRI. We’d like 

20 to again go on record stating that we feel the E21 sub-b is more appropriate to rate the furnace fan 

22 efficiency. When we provided the proposal to DOE, 

23 we had to consider furnaces with single stage 

24 controls, two stage controls, as well as step 

25 modulating controls. And again, it comes down to 
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1 the scope definition, or the scope coverage point 

2 that we made earlier with respect to furnaces. But 

3 the reference system that’s being discussed here, 

4 there could be cases where the rise range that is 

5 specified in the nameplate of furnace manufacturers 

6 could be beyond the rise range that is specified, 

7 and so it could cause safety concerns. I think 

8 either Dave Wittingham or Greg Wagner pointed this 

9 out earlier as well. So we urge DOE to consider 

10 that as far as this issue is concerned. 

11 MR. BROOKMAN: Okay. Jim Vershaw, you’re 

12 next. 

13 MR. VERSHAW: This is Jim Vershaw, 

14 Ingersoll Rand. Back to my question about heating 

15 speed maximum being higher than the cooling speed. 

16 If I looked ahead, it looks like they’re going to 

17 take the maximum air flow speed, multiply that by 

18 cooling hours. So if you have a heating speed 

19 that’s higher than cooling speed, then you’re 

20 multiplying the wrong numbers, and then that throws 

21 the whole calculation into some question as to the 

22 accuracy of it. 

23 MR. BROOKMAN: Sam. 

24 MR. JASINSKI: Yes, that’s a very good 

25 point. If interested parties could provide 
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1 information regarding how prevalent the designation 

2 of the maximum setting for heating is, that would be 

3 appreciated. Again, the assumptions that we provide 

4 in terms of designated air flow control settings for 

5 specific functions are meant to represent the 

6 national average, or what is typically done. So if 

7 we get -- if DOE can get a sense of how significant 

8 that trend is in designating the maximum speed for 

9 heating settings, that is something that we 

10 definitely want to consider and want to account for. 

11 So if interested parties can provide information 

12 regarding that, that would be very helpful. 

13 And on to his further point, that would 

14 also impact how the other calculations are 

15 considered. 

16 MR. BROOKMAN: Harvey. 

17 MR. SACHS: Harvey Sachs, ACEEE. I 

18 believe that our community will be very 

19 uncomfortable with consideration of E-sub-b as a 

20 replacement for what the Department is trying -- is 

21 groping towards proposing. At the risk of 

22 prolonging the discussion, E-sub-b was developed as 

23 a threshold mechanism for incentive programs that 

24 wanted to recognize efficient air handlers. For 

25 condensing furnaces only, it’s not a bad 
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1 discriminator between ECM and PSC motored systems. 

2 I was unable to get a decent discriminator of that 

3 type when trying to analyze non-condensing furnaces. 

4 There was simply much more variability. And at this 

5 point, without a great deal more empirical data, I’m 

6 forced to conclude that this is an inappropriate 

7 metric for the Department’s purposes, and that 

8 furthermore, any threshold metric, unless AHRI is 

9 proposing to extend it from just a two percent 

10 threshold to an actual value, will serve to 

11 discourage incremental innovations that would save 

12 energy, because there’s only a single huge cliff to 

13 climb. 

14 MR. BROOKMAN: And you’re referring to E15 sub-b? 

16 MR. SACHS: I’m referring to the AHRI 

17 proposal of using E-sub-b instead of the kind of 

18 metric that DOE is proposing for which I may have 

19 different reservations. 

20 MR. BROOKMAN: Charlie Stephens. Pardon 

21 me, Charlie, let’s let AHRI respond. Roy. 

22 MR. ROY: In defense to the E-sub-b 

23 metric, actually I think Harvey was alluding more to 

24 the little “e” metric, the bold, italicized little 

25 “e” metric. 
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1 MR. SACHS: Yes. 

2 MR. ROY: Which is different from E-sub-b 

3 in the sense that that metric, in the numerator, it 

4 accounted for the furnace fan electrical consumption 

5 as well as other electrical consumption within the 

6 furnace. However, the industry took a look at that 

7 metric again and revised it substantially to remove 

8 other electrical consumption from the furnace, and 

9 only captured the furnace fan electrical efficiency. 

10 MR. SACHS: But it’s still a threshold 

11 value, or are you proposing to publish the actual 

12 value -- 

13 MR. ROY: No, we are not proposing any 

14 threshold value. It’s just a ratio of the furnace 

15 fan efficiency over the total consumption, energy 

16 consumption of the furnace. 

17 MR. SACHS: I certainly look -- Harvey 

18 Sachs again. I certainly look forward to looking at 

19 that and appreciate that you’ve addressed those 

20 issues. 

21 MR. BROOKMAN: If I understand you Roy, 

22 you are providing essentially a rating? 

23 MR. ROY: This was a proposal that we 

24 submitted because we were aware of the furnace fan 

25 rulemaking 
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1 MR. BROOKMAN: Which would supply a 

2 rating. 

3 MR. ROY: Right. 

4 MR. BROOKMAN: Charlie Stephens. 

5 MR. STEPHENS: Charlie Stephens. This 

6 sort of -- it’s a good introduction to what I was 

7 going to have to say, because I don’t -- where I 

8 live, we don’t pay much attention to those annual 

9 numbers. The consumption number, and therefore the 

10 percentage of a consumption number doesn’t mean 

11 anything much to us either. The variability of that 

12 number where I live is just too great. You know, we 

13 work all the way from 3000 degree days to over 9000. 

14 And it’s just -- those numbers don’t mean anything. 

15 And in fact, I’m having to look at this particular 

16 procedure as a way to rate a product, but I can’t 

17 say that I’ve seen any usefulness or utility coming 

18 out of this rating that would help me understand 

19 what any given product would use in the way of 

20 energy. All it does is, in theory, allow us to 

21 compare one product against another on some sort of 

22 close to apples-to-apples basis. But I don’t think 

23 it’s going to deliver a metric that’s going to be 

24 useful to me in terms of understanding the energy 

25 consumption of the product. And so I have no 
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1 expectation of that. 

2 MR. BROOKMAN: Yes, Dave. 

3 MR. WITTINGHAM: This is Dave Wittingham 

4 with Allied Air. First of all, I just would like to 

5 comment on your chart. The chart is showing 

6 characteristics that are typical of a PSC 

7 application, where you have a constant air volume, 

8 variable speed, more highly efficient system those 

9 curves would look significantly different, where the 

10 top lines would look flat and the watts would 

11 actually be going in the opposite direction that you 

12 show. And kind of the thought process behind that 

13 in this type of application, you may be penalizing 

14 the more efficient products. That’s kind of point 

15 one. 

16 Point two is you’re taking nine points of 

17 data and then doing a curve fit, and it’s a very 

18 cumbersome, labor intensive, and resource intensive 

19 process that would require a completely different 

20 setup from the typical AFUE testing that is done for 

21 gas products. We would advocate that, you know, E22 sub-b is something that comes easily out of the AFUE 

23 testing, that we would highly encourage the 

24 Department to look at. Whatever the metric is 

25 decided, is to have something that is easily 
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1 accomplished within those test setups without 

2 forcing an additional test setup. 

3 Yes, manufacturers do air flow testing, 

4 but we don’t typically run two or three or four 

5 models to get the type of statistical data that 

6 would be required to develop a rating, and this 

7 would be a significant additional burden. 

8 MR. BROOKMAN: Thank you. Terry. 

9 MR. SMALL: Well, I think that we’ve all 

10 understood that the consumer of this type of 

11 information is Charlie, and Charlie is sitting here 

12 telling us that he’s not seeing anything that is 

13 worth consuming, and Dave is saying that it is going 

14 to be a massive burden on the industry. Dave’s with 

15 a big company, it would be catastrophic for a little 

16 company. So what are we doing here? 

17 MR. BROOKMAN: Charlie Stephens. 

18 MR. STEPHENS: I didn’t say nothing was 

19 useful, I just said that I have no expectation that 

20 an energy use number is useful. But I do find 

21 apples-to-apples comparisons useful, if I believe 

22 that they’re truly that. I don’t know that we can 

23 get there or not. We’re working on it. 

24 MR. BROOKMAN: You’re talking about the 

25 consumer. 
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1 MR. STEPHENS: Well, the consumer -- the 

2 consumer almost never sees this stuff. The consumer 

3 is -- yeah, incentive programs, contractors who want 

4 to sell something or another, and explain to a 

5 consumer what it is they’re selling relative to -- 

6 that costs more than this other one that costs less, 

7 you know, the consumer ultimately will see ratings 

8 of some kind, and that’s useful, and we can teach 

9 them to understand what they mean, and we are. But 

10 ultimately, we’re trying to understand, in our 

11 climate where I live, with this product, a 

12 reasonable estimate of how much electricity it’s 

13 going to use in doing its job annually. I would 

14 like to know that number, but this is one of those 

15 cases that when you average everything, you get a 

16 number that applies to less than one percent of the 

17 installations, and it’s just not useful. What I 

18 need is a rating tool that allows me to then adjust 

19 that and maybe a disclosure of some data from the 

20 testing that allows me to pick which points are 

21 relative to where I live, and come up with my own 

22 number. That would be useful. 

23 MR. BROOKMAN: Greg. 

24 MR. WAGNER: I was just going to say, 

25 Charlie, you just touched on one of the challenges 
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1 with doing what’s being done here, and that is 

2 aggregating across the US all these different things 

3 to try to put together some kind of single metric 

4 that allows you to say this is the energy 

5 consumption of this product. And so it addresses 

6 the issue of nobody, as Charlie was just saying, in 

7 terms of being able to give them exact performance 

8 and mileage that they’re going to expect. 

9 But taking it away and putting it into CFM 

10 and these other things, takes it an even further 

11 step away from you being able to understand what it 

12 means in any installation application, and that is 

13 what typically is done is figuring out what is that 

14 heat load which goes into the number, heating 

15 degree, cooling degree days that you put into your 

16 calculations to generate the number of hours used. 

17 And removing -- separating the performance of the 

18 fan from the performance of the furnace is creating 

19 this two different metric system, but then even a 

20 consumer is going to have difficulty understanding 

21 how do I value the fan performance versus the 

22 furnace performance, because they are going to be 

23 two separate things, and not necessarily as one of 

24 my colleagues here mentioned, not necessarily along 

25 a rating line where this thing could be safely 
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1 operated. So it’s taking it multiple levels away 

2 from getting back to what Charlie was wanting, to be 

3 able to specify the right product for your 

4 application in the field. 

5 So it sounds like it’s not serving a whole 

6 lot of functions versus if we can get something that 

7 is tied to performance and capacity of the unit, we 

8 can get something ultimately that enables people to 

9 supply it appropriately and put together an energy 

10 descriptor that allows you to measure it, rate it 

11 appropriately, and give the consumer something they 

12 can use. 

13 MR. BROOKMAN: Craig. 

14 MR. MESSMER: As I’m listening to 

15 everybody, this is Craig Messmer, I’m wondering 

16 about some advanced technologies that are starting 

17 to pop up out there where the air flow varies with 

18 temperature in the room, so there is no high, 

19 medium, or low speed. The unit continuously varies 

20 itself. What do we do there? Now you need a BIN 

21 analysis for the house application, or the average 

22 house, which doesn’t exist, but it’s nice. So 

23 that’s a technology that is maybe up and coming, 

24 it’s not even considered. It’s not an ECM, it’s not 

25 a -- well, the motor might be, but the control 
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1 scheme is different, it’s not set by discrete speeds 

2 or CFM. So how do we handle that one? That’s a 

3 question. I don’t have an answer. 

4 MR. BROOKMAN: Additional comments on this 

5 series of issues? 

6 MR. JASINSKI: I have a couple of follow 

7 up questions. Dave, you mentioned that the curves 

8 for a higher efficiency unit would be very different 

9 and we agree. Unfortunately, I don’t have a similar 

10 figure to put up here for everyone to see, but just 

11 to reiterate, Dave said that the air flow curves 

12 would look more straight, meaning that at higher 

13 external static pressures, a higher efficiency motor 

14 would be providing a constant volume of air, so it 

15 would be achieving a higher air flow at higher 

16 external static pressures, and as a result, because 

17 it was able to maintain the air flow at those higher 

18 external static pressures, the electrical 

19 consumption curve would go up because it would need 

20 more power to provide that constant volume of air. 

21 So, in an attempt to account for that in 

22 this metric, that was one of the reasons why we 

23 normalized by air flow in the maximum control 

24 setting so that if you were normalizing say for this 

25 particular fan, the maximum’s going to be about 1050 
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1 at the reference systems being proposed, whereas if 

2 you were doing this for a higher efficiency one, 

3 that curve would look flat and that air flow might 

4 be somewhere closer to 1300 or maybe even at 1400. 

5 So if you could comment maybe on -- I don’t know if 

6 you’ve looked at it closely enough -- whether or not 

7 normalizing by air flow in the maximum control 

8 setting sort of avoids that issue of penalizing 

9 higher efficiency motors. 

10 MR. WITTINGHAM: This is Dave from Allied 

11 Air. We have looked at it. There’s more study that 

12 needs to be done around that to really understand if 

13 that holds true. 

14 MR. JASINSKI: Okay. Yeah, if you could 

15 provide whatever you find, that would be very 

16 helpful. 

17 And then another point was, Dave also 

18 brought up the issue of when you’re taking the data 

19 and the burden or the changes to the setup that that 

20 would require as opposed to what they currently do 

21 now, whether you want to do it now or provide it in 

22 your written comment, if you could just explain 

23 where those burdens come in because I guess a way to 

24 look at this would be, there’s the burden of 

25 actually taking the measurements, and then there’s 
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1 the burden of what you do once you have those 

2 measurements. So -- you were speaking more to what 

3 you do once you have the numbers, which are 

4 calculations and creating these quadratic curves, so 

5 if you could explain how -- explain or provide an 

6 estimate of the magnitude of that burden maybe in 

7 terms of cost or time or systems or equipment that 

8 you would need to do that, that would be helpful. 

9 MR. WITTINGHAM: Actually my comments were 

10 around the actual generation of the actual test 

11 points. 

12 MR. JASINSKI: Okay. 

13 MR. WITTINGHAM: You know, I am assuming -

14 - and we’ve already done some work around here -- 

15 that you could take, once you have the data, you can 

16 put it into a calculation relatively simply. Yes, 

17 there is some up front work that needs to be done, 

18 and it’s time consuming, but that’s not -- and every 

19 time that you run it, the resource effort or the 

20 time and the cost that’s involved with the setup and 

21 the running of the test, which in our estimation is 

22 almost a shift’s worth of work for one model. 

23 MR. BROOKMAN: Charlie Stephens. 

24 MR. STEPHENS: I’ll just add one thing 

25 about the fact that I do this already with a 
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1 different air handling product. I do it every day. 

2 It’s called an HRV, and if you look in the HVI 

3 directory in Section 3, you’ll see that those 

4 products have been tested in at least four different 

5 external static points, and they show the power 

6 consumption at those four points, and the air flow 

7 at those points, and all I have to do is decide what 

8 my target external static is or what I think he 

9 external static is going to be and I can figure out 

10 how much energy that thing’s going to use for as 

11 many hours as it’s running. Throw in the hours that 

12 I expect to run it, and I have an answer for how 

13 much energy I’m going to use to do ventilation. 

14 It’s really not that hard. C439, you know, delivers 

15 those numbers, and all the manufacturers test to 

16 those things, and I find it very useful. Every day. 

17 MR. BROOKMAN: Terry. 

18 MR. SMALL: So Charlie, you already have 

19 it, basically. 

20 MR. STEPHENS: The Canadians do, in C439, 

21 and those things are tested and it’s in a directory 

22 that I can use. Yeah. But it’s not for air 

23 handlers. 

24 MR. SMALL: None of the equipment 

25 manufactured in Canada is typically manufactured 
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1 here, so -- 

2 MR. STEPHENS: A lot of it is manufactured 

3 here, and a lot of it is manufactured in Europe and 

4 other places. But I mean, the fact is, they’re all 

5 testing to a test method that gives me the metrics 

6 that we’re talking about here: air flow, energy 

7 consumption, external static, ducts. 

8 MR. SMALL: So you want the multiple 

9 metrics and not the single value? 

10 MR. STEPHENS: Well, if they come out of 

11 the test procedure, then I can figure out the energy 

12 consumption from my application. It may not be the 

13 rating. These things are rated differently. 

14 They’re rated by apparent sensible effectiveness, or 

15 sensible recovery efficiency. But I have the tools 

16 I need to figure out how much electricity they’re 

17 going to use and whether they’re going to use more 

18 than they say. The range is like point three watts 

19 per CFM up to two watts per CFM, so it kind of 

20 matters. 

21 MR. BROOKMAN: Any other comments on this? 

22 Yes, Craig. 

23 MR. MESSMER: Is it appropriate to talk 

24 about tolerances in this slide, or are we going to 

25 talk about that later? 
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1 MR. JASINSKI: Later we’re going to talk 

2 about sampling plan criteria, and that will probably 

3 be more applicable to that conversation. But I’ll 

4 remember that you want to talk about it, so if it 

5 doesn’t come up, then -- 

6 MR. MESSMER: Well, it will. 

7 MR. JASINSKI: And if it relates more to 

8 measurements of air flow, then sure it’s relevant, 

9 always. 

10 MR. BROOKMAN: I was -- well, where did 

11 you think tolerance fits in this? 

12 MR. MESSMER: The fan curves, the blue 

13 lines, the red line, solid lines -- all the lines up 

14 there. You have three points, but there is a 

15 scatter, of course, so how big is that scatter. 

16 Could be very significant in some cases. So we have 

17 to factor that in somewhere, especially if you’re 

18 going to have a fan rating. And more to Charlie’s 

19 point, I agree, if we just -- our catalogues give 

20 you CFM versus watts, and static pressure fan curve 

21 -- anybody can look at the fan curve and figure out 

22 what the energy consumption for that application is. 

23 I think most manufacturers already do that. So I’m 

24 not sure what a rating point is going to help, 

25 because you cannot compare two systems and two very 
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1 dissimilar hydronic air handlers versus gas 

2 furnaces, versus gas/electric, somebody’s going to 

3 come up looking bad when in fact they may be the 

4 best solution for that house. 

5 MR. BROOKMAN: Okay? 

6 MR. JASINSKI: Yes, thank you. So sort of 

7 related to what Craig was saying is that you see in 

8 that figure that there’s a wide range of operation, 

9 but not that entire range is not always necessarily 

10 relevant. So, for instance, in the maximum control 

11 setting, operating at zero external static pressure 

12 doesn’t probably occur that often in the field. So 

13 in order to identify the parts of the points of 

14 operation that are relevant, DOE proposes to use a 

15 reference system. And the reference system 

16 represents national average ductwork 

17 characteristics, which allows for comparison of fan 

18 performance across different operating -- common 

19 operating conditions across different products. And 

20 the reference system takes the form of a curve that 

21 relates the external static pressure to air flow, 

22 represented by Q in this equation, and the physical 

23 characteristics of the system, K, in this situation. 

24 So the physical characteristics of the system -- so 

25 a system in a field application would be the actual 
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1 home and the ductwork itself. In the context of 

2 testing, K here would describe the test setup. 

3 And for this test procedure, DOE is 

4 proposing to define the reference system by a 

5 specified external static pressure value and the air 

6 flow delivered by the fan at that ESP value in the 

7 maximum air flow control setting. So here is just 

8 sort of a manipulation of that previous equation, 

9 showing what I’m describing and how the reference 

10 system is proposed by DOE. 

11 So, in order to determine what an 

12 appropriate reference system value would be, DOE 

13 decided that it would be more appropriate to try to 

14 base the specified value on field operation. And 

15 while DOE shares the concerns that ductwork and 

16 things beyond DOE’s control might attribute to 

17 improper use, DOE is limited in what it can regulate 

18 under the statutory language, and wants to provide a 

19 rating metric that is indicative of -- 

20 representative of field use. 

21 So DOE followed the following methodology 

22 for determining what an appropriate representative 

23 ESP value or reference system ESP value would be. 

24 DOE compiled over 1300 field measurements of 

25 external static pressure in maximum air flow control 
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1 settings. During this work DOE identified four 

2 different types of installation as it pertains to 

3 reference systems: 

4  heating only units, which are units that are 

5 not designed to be paired with an external 

6 evaporator coil and don’t an internal 

7 evaporator coil. 

8  Second, units with an internal evaporator 

9 coil. An example of these units might be 

10 weatherized gas furnaces where the condensing -

11 - excuse me, the evaporator coil is internal to 

12 the system for cooling. 

13  Thirdly, units designed to be paired with an 

14 evaporator coil. These are units, as it says, 

15 are designed to be paired with an evaporator 

16 coil, but these evaporator coils are typically 

17 separate components and they are paired with 

18 them in the field, they are not shipped with 

19 the evaporator coil factory installed. 

20  And lastly, manufactured home units which 

21 anyone who’s familiar with the furnace 

22 rulemaking, requires special consideration 

23 because of the space constraints and other 

24 separate codes that manufactured home units 
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1 have to meet which impact the expected external 

2 static pressure of systems installed in 

3 manufactured homes. 

4 In going through this data, the third 

5 thing that DOE had to do was normalize the data for 

6 comparison, and in this case what I mean is that in 

7 certain reports some of the reports provided data 

8 that included the -- the ESP values included the 

9 evaporator coil pressure drop, some didn’t. Also 

10 some included the filter pressure drop, and some 

11 didn’t. So what DOE did was took the data and 

12 developed a value -- two values for each reported 

13 value, one that included the reported value for 

14 evaporator coils, and one that did not. And all of 

15 them included a pressure drop for the filter. So 

16 essentially what DOE did was took some of the 

17 studies which included estimations of evaporator 

18 coil pressure drop and filter pressure drop and 

19 determined a representative value for those pressure 

20 drops. And the reported value for an evaporator 

21 coil was point two inches water column, and the 

22 reported average pressure drop reported for an air 

23 filter was point two one (.21) inches water column. 

24 So in this table, you can see the results 

25 of those studies where in single family homes, the 
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1 with coil external static pressure was around 0.73 

2 inches water column, and without coil was 0.52. And 

3 in addition, for manufactured homes, it’s much 

4 lower, at 0.37 for the with coil external static 

5 pressure, and 0.17 without. So the reason DOE 

6 determined two values was because not all -- one was 

7 because of the variation in the installation type, 

8 whether or not a unit has an internal evaporator 

9 coil, is designed to be paired with one. 

10 And the fourth step, because not all units 

11 that are designed to be paired with an evaporator 

12 coil are actually paired with one in the field, DOE 

13 used EIA’s RECS 2005 data to determine the 

14 percentage of furnaces or units that don’t have an 

15 internal evaporator coil but are paired -- designed 

16 to be paired with one actually are in the field. 

17 And so the results of that are, 72.9 percent of non18 weatherized gas and oil furnaces in single family 

19 households are paired with evaporator coils, and 

20 50.2 percent of units designed to be paired with an 

21 evaporator coil are paired with an evaporator coil 

22 in manufactured home households. 

23 So DOE then took these two values and did 

24 a weighted average to determine the reference system 

25 for units that are designed to be paired with an 
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1 internal evaporator coil. So you see here these are 

2 the same results, rounded to the nearest five3 hundredths of an inch water column. So heating only 

4 units that are not designed to be paired with a 

5 coil, they assume the rounded value of the without 

6 coil for single family homes, which is point five 

7 inches water column. And remember, that this is in 

8 the maximum air flow control setting. 

9 The units with an internal evaporator coil 

10 do not include the pressure drop in evaporator coil 

11 because that pressure drop is already accounted for 

12 in the results of the test based on the description 

13 on where the sensors are placed as I described 

14 earlier in the test setups. So that does not need 

15 to be accounted for in the reference system of 

16 external static pressure. 

17 Units designed to be paired with an 

18 evaporator coil, as I explained, DOE did a weighted 

19 average using that RECS 2005 data to determine that 

20 a representative value for units designed to be 

21 paired with an evaporator coil would be 0.65 which 

22 uses the 72.9 percent weight for the with coil and 

23 then the remainder of without, and the result is 

24 0.65 inches water column. And manufactured homes, 

25 0.3. 
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1 MR. BROOKMAN: Craig. 

2 MR. MESSMER: Craig Messmer. I feel 

3 obligated to point out that small duct systems 

4 operate at much higher static pressures than that. 

5 I’m sorry to say I don’t have a field study, though, 

6 so is there any intention to do a field study on 

7 that? 

8 MR. JASINSKI: Yes, we will collect any 

9 data that we can find, so if you can provide 

10 anecdotal -- 

11 MR. MESSMER: We can give you addresses. 

12 MR. JASINSKI: -- data -- okay. 

13 MR. MESSMER: Could you back up just one 

14 slide, though on that. I’m just a little confused 

15 why the coil -- with coil is a higher external 

16 static pressure, and without a coil it’s less than. 

17 It doesn’t make any sense to me. 

18 MR. JASINSKI: So, in these cases, the 

19 with coil is -- the measurements were taken where 

20 the system was paired with an evaporator coil, and 

21 that evaporator coil pressure showed up in the field 

22 measurement. So essentially, I guess an example 

23 would be a furnace, if tested alone would probably 

24 be closer to the 0.5, but because it was paired with 

25 an evaporator coil, meaning the coil was present in 
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1 the furnace, which is a separate product and not 

2 indicative of how it ships from the factory, that is 

3 included. 

4 MR. MESSMER: So is the coil part of the 

5 internal static pressure? Which column? 

6 MR. JASINSKI: On the right. Internal 

7 static pressure -- this is external static pressure. 

8 MR. MESSMER: Yeah. 

9 MR. JASINSKI: I just want to make sure 

10 everyone else heard that. 

11 MR. MESSMER: I’m just a little confused 

12 as to why when you have a coil as part of the 

13 product, you’re external static pressure is going to 

14 be higher, which means better performing at the same 

15 CFM, right, better -- more capacity. 

16 MR. JASINSKI: Maybe I’ll go -- let me go 

17 back to that diagram, because it’s easier I think, 

18 to understand what needs to be included in the 

19 external static pressure when you know where the 

20 pressure measurements are being taken. So, correct 

21 me if I’m wrong, but the question is why does the 

22 without coil -- why is the without coil external 

23 static pressure lower, and why is with higher. 

24 MR. MESSMER: Yes. 

25 MR. JASINSKI: So the external static 
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1 pressure, you can think of it as the pressure that 

2 the test system is applying to the product being 

3 tested. So for units that are designed to be paired 

4 with a coil, they don’t ship with that coil 

5 installed, so the external static pressure, or the 

6 pressure that’s applied by the test system has to be 

7 higher to account for how that -- to account for 

8 that coil that’s not present in the test system but 

9 will be in the field. 

10 MR. MESSMER: Yeah, I get that part, but I 

11 -- 

12 MR. JASINSKI: Oh, then maybe I’m 

13 misunderstanding your question, I’m sorry. 

14 MR. BROOKMAN: Charlie Stephens. 

15 MR. STEPHENS: Yeah, I think -- let me see 

16 if I can get this right. Take a heat pump indoor 

17 unit that’s got an indoor coil, you would apply 

18 point five inches outside to that because the point 

19 two inches, which they figured out for a coil, is 

20 internal to that unit already. 

21 MR. MESSMER: Right, it would be. 

22 MR. STEPHENS: And so they only have to 

23 apply point five inches to that. My -- I may have 

24 the same questions for them that you do, but I think 

25 what he’s explaining is when you’ve got a furnace 
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1 that doesn’t ship with a coil, then you add the coil 

2 to the external static applied by the system, the 

3 testing system, so that you get the same level of 

4 total static pressure. 

5 MR. BROOKMAN: Craig. 

6 MR. MESSMER: You are correct. The table, 

7 the average table is accurate. I’m just trying to 

8 correlate it to the table of the data. It doesn’t 

9 make any sense to me -- what the results of this -- 

10 MR. JASINSKI: I understand. The results 

11 here show the adjusted values, and so these adjusted 

12 values have the representative pressure drops that I 

13 mentioned previously. So, for instance, depending 

14 on how the data was reported, the point two for the 

15 evaporator coil was added in if the data reported in 

16 a specific report did not include that pressure drop 

17 in the measurement. 

18 MR. MESSMER: I’m okay with your final 

19 charts which -- the next one -- that’s the only 

20 important one to me, the other one didn’t. So we’ll 

21 move -- I’ll maybe sidebar later. 

22 MR. JASINSKI: Yeah, sure. 

23 MR. BROOKMAN: Dave. 

24 MR. WITTINGHAM: Yeah, I just had a 

25 question around, you know, you’ve got the 1300 
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1 samples. How were those measurements made and was 

2 there any analysis about how those measurements 

3 would correlate to a lab-type setup that we’re 

4 talking about through the standard you referenced, 

5 or ASHRAE 37? 

6 MR. JASINSKI: Yes, so the -- these 

7 numbers come from various reports that date from as 

8 recently as 2010, I believe, back to some earlier 

9 papers that were in the late 90s. So most of these 

10 data points come from field measurements. And they 

11 were measured in accordance with AMCA 210. 

12 MR. BROOKMAN: Jim Vershaw’s next in the 

13 queue. Jim, go ahead. 

14 MR. VERSHAW: Hello, Jim Vershaw, 

15 Ingersoll Rand. A couple of points. Number one, if 

16 I was going to pick a static pressure, I’d take 

17 point five, that’s part of my residential, non18 weatherized furnaces -- most of those, not all of 

19 them, have a point five maximum static pressure on 

20 the nameplate that we get our state certification 

21 around. So the point five would be the more logical 

22 place to go. 

23 The second point would be the definition 

24 of a heating only unit for a residential, non25 weatherized furnace, I don’t think I’ve ever seen a 
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1 heating only unit, but I can envision -- but I can 

2 create all my furnaces to be heating only in that 

3 they’d only have cooling by relay, and therefore I 

4 can test them all at lower external statics, and I 

5 would eliminate that -- I would eliminate cooling 

6 from the whole thing. But if you have to go to 

7 cooling, I would eliminate the heating only. 

8 Thanks. 

9 MR. BROOKMAN: Okay. Thank you. Greg. 

10 MR. WAGNER: Greg Wagner -- 

11 MR. BROOKMAN: Is your mic turned on? 

12 MR. WAGNER: I apologize. Greg Wagner. 

13 Regarding the studies, you mentioned 1300 analyzed, 

14 how was this standardized for validating capacity 

15 versus requirement in the field? It would be 

16 important to know how those relate because again, 

17 the capacity and the function of the device is going 

18 to vary depending on what the actual installation 

19 requirements are. So oversizing product will lead 

20 to much, much higher statics in the field. 

21 The second thing is, and you started to 

22 mention a test standard. AMCA 210 is not applicable 

23 to that kind of a testing, and I doubt anybody has a 

24 full air test chamber that is large enough, enough 

25 diameter -- we’re talking about probably a ten-foot 
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1 diameter for most of these to build a -- to be in 

2 concert with AMCA 210. So what test standard were 

3 these measurements done by? I mentioned earlier I 

4 don’t believe static pressure measurements. This is 

5 from 30 years of experience in dealing with air 

6 flow. Static pressure measurements are notoriously 

7 bad and they’re difficult to get in a laboratory 

8 environment. They’re even worse to get in the 

9 field. So just that question, I’d like to 

10 understand that. You know, were these with filters, 

11 without filters? What was that filter condition? 

12 How were these things done? 

13 Further on, you know, we’re talking about 

14 adding to the testing burden by adding a secondary 

15 test point versus what’s already required under DOE 

16 for testing of furnaces today. So it’s arbitrarily 

17 adding another static point that’s based upon data 

18 which, again, I’d like to understand where those 

19 points come from. 

20 Then, finally, or not finally, but 

21 additionally, we’re sending messages to installers 

22 that it’s okay to do bad practices, that high static 

23 conditions are acceptable, that we should want to 

24 keep perpetuating that. That’s not a good message. 

25 We’re also losing the signaling effect and that is, 
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1 when a homeowner would buy this thing, and they’re 

2 finding they’re not getting the performance they 

3 need, they need to find out why it is. Well, if 

4 you’re saying that you should be running with these 

5 high statics and they see that they’re performance 

6 is mediocre, they’re going to say, okay, it’s what 

7 it calls for because that’s what the rating system 

8 calls for. Rather than saying, now I’m capable of 

9 getting 30 miles per gallon out of my car, but I’m 

10 only getting 25, what the heck’s going on here. We 

11 need to push things so people understand that there 

12 are appropriate ways of doing this, and they can 

13 benefit from that. 

14 And then finally, we need to use this also 

15 as a way to verify out in the field, I think, that 

16 people are getting the product they want. And I 

17 think that’s what I hear a lot of folks saying. How 

18 do we make sure that we’re doing the right things in 

19 the field? And that’s where tying these to what 

20 should be done, versus not what is currently done in 

21 terms of bad practice. 

22 MR. BROOKMAN: Charlie Stephens. 

23 MR. WAGNER: Charlie, could you wait until 

24 we hear what the database was? 

25 MR. BROOKMAN: You want -- yeah, let’s let 
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1 him respond. 

2 MR. JASINSKI: Yes, because otherwise, I’m 

3 going to forget all five of those points. So just 

4 to talk about -- you mentioned that people aren’t 

5 using the AMCA 210 setup in their homes to get these 

6 measurements. What I should revise what I said and 

7 mean that in looking at how the measurements were 

8 taken, the -- this goes back to the whole external 

9 static pressure discussion that we had, is that we 

10 tried to make sure that when they referred to 

11 external static pressure in these studies that 

12 theoretically they were the same types of pressure 

13 measurements that were specified in AMCA 210, you 

14 know, placement of the sensors -- that that data 

15 would be -- I mean you can’t -- obviously, you can’t 

16 take an AMCA 210 test setup into the field. I mean 

17 it is field data. 

18 The second thing is that, well, related to 

19 that, all of the studies that were used, that we 

20 could make public, are included in the docket in PDF 

21 form, so I would encourage everyone that takes issue 

22 with the results or the methodology of gathering 

23 this information, to look at those studies and point 

24 out why some studies might be appropriate and some 

25 may not, or some of the limitations of how we can 
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1 use that data based on things, factors that Greg 

2 mentioned, such as this study doesn’t mention 

3 whether or not the filters had just been changed or 

4 had it, or whether or not it’s included. This was 

5 the methodology DOE used based on the data that it 

6 could find. If you have other data, better data, we 

7 would really appreciate that you submit that also. 

8 MR. WAGNER: Greg again. AMCA 210 

9 requires that you have good, fully developed flow to 

10 be able to get a pressure measurement. Or you have 

11 a large air test chamber that allows that flow to 

12 stabilize and create a reasonable expectation of 

13 good static pressure measurement. That’s not 

14 possible in any of these field installations. So I 

15 guess my question is it’s not to AMCA 210. I’ve 

16 read enough of them to know it’s not to that. What 

17 standard are these to, because that is -- that’s not 

18 apparent from any of these? And then how did they 

19 correct for temperature, barometric pressure, et 

20 cetera, to a standard condition? And then, finally, 

21 you have all the field effect things which are how 

22 are you comparing capacity to what the need of the 

23 dwelling is? Filter and other things. So it’s not 

24 just the basic static pressure, but it’s also those 

25 other attended variables as well. I don’t know that 
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1 I’ll have time to get through all however many, 1300 

2 of those applications before the comp period’s due 

in July 30th 3 , but I think that onus should be upon 

4 the folks that are putting together this analysis to 

5 substantiate that those measurements comply with 

6 some known standard, not just arbitrary measurements 

7 that were made by different folks. 

8 MR. JASINSKI: Alex is a little bit more 

9 familiar with some of these studies than I am, so 

10 maybe he can provide a little bit more insight as to 

11 some of the standards that may have been used. 

12 MR. BROOKMAN: Let me make a process note. 

13 In a little bit we’re going to break for lunch, kind 

14 of regardless of how far we advance at the moment. 

15 So, Alex, go ahead. Alex Lekov. 

16 MR. LEKOV: Alex Lekov, LBNL. As 

17 mentioned, this is based on studies formerly 

18 published on Page 60 and 61 of this presentation. 

19 So some of the, or most of the studies are actually 

20 presented in public forums and conferences, and 

21 discussed. Detailed spread sheets are associated 

22 with almost every single one of them. Some of them 

23 have a lot of details in the reports themselves. 

24 And when the data was compiled, DOE’s team actually 

25 did their best to create conditions to compare above 
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1 variables. 

2 So, in terms of your statement, as part of 

3 formal comment, we could provide this assessment, 

4 why these studies are relevant. But this is 

5 actually a body of knowledge that has been collected 

6 by a lot of parties over the last probably 12 years. 

7 MR. WAGNER: You’re the expert to be able 

8 to tell me what standard they were done to? I mean, 

9 that’s what I’m trying to find out. It’s not clear 

10 from the papers. 

11 MR. LEKOV: It’s -- this is the way those 

12 measurements are done in the field. People measure 

13 the temperature differences appropriately. They -- 

14 most of the studies actually talk about the 

15 corrections, appropriately done. They list whether 

16 the system is with coil or not, with filter or not. 

17 So there are a lot of details. Studies come also 

18 with the raw data. We contacted most of the 

19 authors, discussed details when something was not 

20 specific. It’s as all this could be and it 

21 basically those are all studies done the last 12 

22 years. 

23 MR. WAGNER: Understood. But I’m saying 

24 they’re not necessarily done to any standard, if you 

25 will. Which standard? 
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1 MR. BROOKMAN: Charlie Stephen. Alex, and 

2 Greg, and now Charlie. 

3 MR. STEPHENS: There are several people in 

4 here, you’ll see there’s usually about four 

5 different groups of people associated with this, and 

6 over the years many of them have actually developed 

7 the standards themselves. I have created the 

8 standards that are being used, and they’re all using 

9 them. They may not be your standard, but this is 

10 field -- this is field measurement, and you get into 

11 the house and you do the best you can in most of 

12 these cases. The filter, I can tell you in our 

13 studies, the filter is not there because a true 

14 float plate meter is in that slot that’s being used 

15 to measure the air flow. And so there’s a lot of 

16 other -- there’s a standard that’s used, there’s a 

17 protocol that’s used that is consistent from study 

18 to study to study. 

19 I won’t represent to you that it’s 

20 comparable to AMCA 210. There might have to be some 

21 adjustments made between the field protocols, but I 

22 will tell you that we will be delivering some new 

23 data that will allow you to also answer some of your 

24 other questions about the load of the house and the 

25 capacity of the system delivering it, and how 
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1 oversized it is, and if there is any correlation of 

2 that, we will be reporting in our data. 

3 But we go to great lengths -- I fund an 

4 enormous amount of data collection out there, and I 

5 welcome to have anybody else spend the money that we 

6 spend and go out and get your own data if you don’t 

7 like ours. But in the absence of better data, all 

8 of which is fully explained in the studies, exactly 

9 how it was done, exactly what corrections are made -

10 - all of that’s in the studies. If you want to 

11 challenge them, read them, and then come talk to me. 

12 MR. WAGNER: Greg again. I have read it, 

13 a number of the studies, particularly the ones put 

14 out by Lawrence Berkeley, and they refer to Pigs 

15 (ph) and others, and I’ve looked at his studies as 

16 well. My point is only if there is a standard for 

17 measuring this, what is that? Is it published? Is 

18 it recognized by ANSI? 

19 MR. STEPHENS: It’s a protocol that’s used 

20 in the field because, you know, this isn’t a 

21 laboratory. You know, people’s homes are not a 

22 laboratory, so that you can’t use a standard, you 

23 use a protocol. There’s a difference there. The 

24 protocol’s a little looser, but the precision of the 

25 instruments is fairly consistent, that’s specified. 
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1 Where the measurement are taken, the limitations of 

2 where the measurements are taken, they’re all 

3 specified in the protocol. 

4 MR. WAGNER: Well, accounting for static 

5 pressures in a not fully developed flow is very 

6 difficult, and I guess -- 

7 MR. STEPHENS: It is, and that’s why 

8 there’s some limitations on where you can take those 

9 measurements, and in some cases we don’t actually 

10 get to take those measurements because we can’t do 

11 that. 

12 MR. BROOKMAN: Okay. Harvey. 

13 MR. SACHS: Harvey Sachs, ACEEE. Greg, 

14 your concerns are very important. I’m a consumer of 

15 this information, not a generator of it. The 

16 underlying questions, I think, that you’re trying to 

17 raise are whether the field protocols, which are 

18 certainly not consensus standards, are giving us 

19 biased data. 

20 There’s certainly distribution, but what 

21 we don’t have real good control of for the obvious 

22 reasons, is whether there are systematic biases in 

23 the measurement protocol that’s used. There are 

24 some systematic biases, but -- of which the most 

25 important may be that the reports I’ve reviewed have 
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1 been predominantly for attic-based equipment and 

2 distribution systems, tends to be newer houses and 

3 tends to be places where the distribution is attics. 

4 I suspect Charlie’s got control with some -- with 

5 crawl spaces, at least, but we have much less for 

6 the stock of houses with basement based. 

7 Nonetheless, the patterns appear to me to 

8 be very consistent. One if of substantially higher 

9 external static. Even in carefully controlled new 

10 houses in California -- a set of 100 that were done 

11 within the last few years -- substantially higher 

12 external static than -- twice as high or more -- 

13 than is reflected in the rate conditions under 

14 210/240. 

15 And the second thing is quite surprising 

16 that people have not been able to establish a strong 

17 correlation between unit capacity and external 

18 static of the duct system. These are the patterns 

19 that have been observed and that pattern of non20 relationship between capacity and system ESP would 

21 seem to be one that would persist even if there were 

22 biases in the reported value. They were actually 

23 offset from some true ESP if we were able to measure 

24 that with well developed flows. So I hope that 

25 helps. 
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1 MR. BROOKMAN: That has given us something 

2 to thing about over lunch. I’m going to suggest we 

3 pause for lunch right now, even though we haven’t 

4 completed the Fan Efficiency Rating. 

5 It’s now 12:55 and takes just about an 

6 hour to get -- if you don’t leave campus, which I 

7 don’t anybody leave campus because you won’t get 

8 back and you’d have to go through security again. I 

9 would say that we’ve really done a deep dive on a 

10 few of these subjects today, and I know that’s 

11 useful to the Department. We also need to make sure 

12 we get through all this material during the span of 

13 the rest of the day when we return from lunch. 

14 So you must wear your badge in the 

15 building. And there’s a big cafeteria, if you go 

16 down to the ground floor and go about 100 yards in 

17 that direction, a big cafeteria. You go up two 

18 flights of stairs, or two escalators, and we can all 

19 go en masse, if you’d like, but we will resume at 

20 1:55, right here in this room. 

21 Let me thank you, we’ve had a very 

22 constructive dialogue, we’ll continue that when we 

23 resume from lunch. 

24 (Whereupon, at 12:55 p.m., the meeting in 

25 the above captioned matter was adjourned for lunch 
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1 recess, to reconvene at 1:55 p.m.) 

2 
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1 AFTERNOON SESSION

2 2:01 p.m. 

3 MR. BROOKMAN: Let’s start back up. So we 

4 covered a lot of ground this morning, and 

5 occasionally we dove deep into the little detour. 

6 We need to stay focused in the afternoon to make 

7 sure we get through all this content effectively. 

8 So I’m going to turn it back to Sam, and he’s going 

9 to pick up where he left off. 

10 MR. JASINSKI: Thanks. Unless anyone 

11 wants to comment further on the proposed reference 

12 systems, I’ll move on. 

13 MR. WITTINGHAM: This is Dave from Allied. 

14 Just one comment that the proposed control settings, 

15 there are a products that have stated limitations 

16 that are below those settings, and operating them at 

17 this range could lead to an unsafe or an unreliable 

18 condition. Thank you. 

19 MR. BROOKMAN: Thank you. So the 

20 Department would love to see that data, it really 

21 would. Aniruddh. 

22 MR. ROY: Aniruddh Roy, AHRI. I just want 

23 to summarize some of the points that have been 

24 brought up with respect to this reference system. 

25 We feel that with this proposal, DOE is condoning 
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1 field installation or practices that could be 

2 contrary to what are specified in manufacturers’ 

3 instruction manuals, as well as maybe even ignoring 

4 the poor ductwork that could be in some of the field 

5 data. That was investigated in the course of 

6 determining these values, so we feel that as far as 

7 reference systems are concerned, it should be 

8 limited to a performance comparison between 

9 products, and not field values. 

10 MR. BROOKMAN: Thank you. Additional 

11 comments? Yes, Harvey. 

12 MR. SACHS: Harvey Sachs, ACEEE. We’ve 

13 been going through this question of the appropriate 

14 external statics a couple of decades now. It’s not 

15 an easy one, but I’m struck by the fact that the 

16 vast majority of air conditioner sales now, and for 

17 the foreseeable future, will be for retrofits and 

18 replacements. They’re not for new construction. 

19 I’ve had ductwork modifications done to get my 

20 turning things, and things like that. I’ve tried to 

21 run the numbers just to get a CCA quality 

22 installation done as a way to differentiate premium 

23 products. The costs of doing things outside the new 

24 construction market, in replacements and remodeling, 

25 are almost prohibitive for almost everyone. It is 
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1 imperative that any ratings we use give information 

2 that has potential utility in the real world. And 

3 the design expectations and the rating points that 

4 point two and point three inches static, exist only 

5 in the clouds. 

6 The studies that have been done of new 

7 construction, to code under Title 24, don’t produce 

8 those values. We have not insisted as part of our 

9 consensus agreements that we go back and rerate air 

10 conditioners at realistic external statics, because 

11 it would require rerating all of those products. 

12 This air handler proceeding is the one 

13 chance we have to give the contractors information 

14 that can be used in design for field conditions that 

15 predominate. Not in our minds, but in the field, 

16 and it would be a terrible pity to throw that away. 

17 MR. BROOKMAN: Charlie Stephens. 

18 MR. STEPHENS: And I would just add to 

19 that that I don’t think DOE really has a choice 

20 here. If I go back to the middle bullet on the 

21 eighth slide here where we talk about the test 

22 procedure, making a reasonable representation of 

23 energy use or efficiency in an average use 

24 condition, that’s not an average use condition in 

25 the laboratory, that’s in people’s homes in this 
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1 case. So I think we have to take this range of real 

2 life circumstances into account to the extent we 

3 can. And I -- and based on our data, I don’t think 

4 what I’m seeing here is terribly unreasonable. It’s 

5 a reasonable range, based on what we’ve seen, even 

6 though the variance can be somewhat large, 

7 especially on the high side. This is reasonable in 

8 our estimation. 

9 MR. BROOKMAN: Okay. Sam, I don’t think 

10 you’ve yet presented slide 34. 

11 MR. JASINSKI: No. 

12 MR. BROOKMAN: So, proceed. 

13 MR. JASINSKI: Slide 34 is using the same 

14 data that was presented earlier as an example for 

15 air flow and electrical consumption, this is using 

16 that same data, here represented are the three 

17 proposed rated air flow control settings. You’ll 

18 notice that the medium high gray curve is gone, and 

19 just to clean up the slide a little bit, I also 

20 eliminated the electrical consumption. But the 

21 point of this slide is to give a graphic 

22 representation of a reference system curve, using 

23 the proposed reference system criteria for this 

24 particular model, would help in showing where the 

25 operating points are, or the relevant points of the 
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1 operating air flow curves are for this particular 

2 model. So, where you can see that for this 

3 particular model is of the installation type of 

4 design to be paired with an evaporator coil, so it’s 

5 been assigned a reference system external static 

6 pressure of 0.65 inches water column. At that 

7 external static pressure, at the maximum air flow 

8 control setting, it delivers 1050 cubic feet per 

9 minute of air, and the equation that’s shown there 

10 is used to develop the rest of the curve which, 

11 where it intersects the other air flow control 

12 settings designates an operating point. So this 

13 effectively shows where this particular model, what 

14 the expected performance at the operating system 

15 using the physical characteristics that are 

16 represented by the reference system. 

17 So this might be a little redundant, I 

18 think we spent a little bit of time already on the 

19 request for comment on the proposed reference 

20 system. We can move along. 

21 MR. BROOKMAN: Yes, any final comments on 

22 the reference system. Greg. 

23 MR. WAGNER: Yeah, there is one comment. 

24 You used originally PSC motors for the standard 

25 baseline, and there you’re showing the air flow 
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1 curves typical of PSC motors. The thing with the 

2 external static pressure being higher, that will 

3 reward the PSC motor application, however it will be 

4 detrimental to the ECM motor type of thing. So, 

5 from using this kind of scheme, a PSC motor driven 

6 furnace fan will have less watts used under this 

7 scheme than it would under using an ARI rating 

8 point, shall we say. And vice verse will happen 

9 with the ECM motor. So it’s going to skew the data, 

10 one in favor, one against. 

11 MR. BROOKMAN: Okay. Harvey, knowing that 

12 we’re trying to move on. 

13 MR. SACHS: Harvey Sachs. So the 

14 translation of Greg’s comment is that DOE is 

15 building a system that will discourage innovation 

16 that would save energy, and would penalize products 

17 that could be sold more profitably as premium 

18 products that do save energy. This does not seem 

19 consistent with the goals of the legislation. 

20 MR. JASINSKI: One particular request for 

21 comment that we have regarding the reference system, 

22 DOE is aware that, as everyone has heard, that field 

23 external static pressures can be higher than 

24 recommended by manufacturers. DOE is also aware 

25 that for the Canadian standard related to air 
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1 handler performance, CSAC 23, which was established 

2 in February 2011, I believe, that they use multiple 

3 reference -- that that standard uses multiple 

4 reference systems, one to represent manufacturer 

5 recommended installation, and another to represent 

6 common, field installation. And the reference 

7 system used for manufacturer recommended 

8 installation is 0.3 inches water column, but I will 

9 point out that there’s a distinction. This is for 

10 the heating setting, which is typically a median air 

11 flow control setting, whereas the NOPR for DOE is 

12 proposing to use the maximum air flow control 

13 setting, which is a higher air flow control setting 

14 and typically designated for cooling. 

15 But the request for comment here is that 

16 DOE would like to know if interested parties feel 

17 that using a similar multiple reference system 

18 approach would give a better indication of overall 

19 performance. But I will preface that with, DOE 

20 cannot set an energy conservation standard using 

21 multiple metrics, so if we did use a multiple 

22 approach, in the end it would have to result in a 

23 single integrated metric. 

24 MR. BROOKMAN: Greg. 

25 MR. WAGNER: Greg Wagner. I participated 
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1 in those CSA meetings in rule development process. 

2 The reason for two levels of that is the same one 

3 we’re having discussion about right now, that we 

4 just previously had here, and that is that the point 

5 six recommendation is not a good recommendation for 

6 consumers and others installing equipment in the 

7 field. And since there wasn’t consensus reached, it 

8 was thought better to have two levels to be able to 

9 help consumers and others distinguish between good 

10 practice and bad practice. And what we want to do 

11 is encourage the good practice to get energy 

12 savings, and not to be codifying bad practice, which 

13 is what the direction of higher statics are leading 

14 us. 

15 MR. BROOKMAN: I’m not sure who would 

16 answer the question, but is the industry in general 

17 still behind either the results or the configuration 

18 of the Canadian standard? Aniruddh. 

19 MR. ROY: Aniruddh Roy, AHRI. In the past 

20 the industry has submitted comments against the 

21 adoption of the CEA 23 2011 standard because it is 

22 significantly burdensome to the industry. 

23 MR. BROOKMAN: That’s a partial answer to 

24 my question, thank you. Harvey. 

25 MR. SACHS: Harvey Sachs, ACEEE. And this 
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1 is really a question directed to Eric, I suspect. 

2 We have -- I have some confusion in my understanding 

3 of the single metric, and I refer particularly to 

4 HSPF, the heating season performance for heat pumps. 

5 And it’s my understanding that the Department does 

6 require publication of the HSPF value for each of 

7 five or six climate zones. And the reason I’m 

8 bringing that up is that I could well imagine an 

9 analogous process that would be hard to challenge, 

10 if, within this single metric we still, for example, 

11 using your FER wound up with zonal FERs depending on 

12 the relative anticipated weight of cooling and 

13 heating. So I’m just not understanding what single 

14 metric means to you. 

15 MR. STAS: Eric Stas, DOE. And I 

16 apologize because I can’t quite recall how HSPF got 

17 into our regulatory system, whether it rose from a 

18 statutory standard, do you recall? 

19 MR. SACHS: I believe that it came in with 

20 the initial batch of seasonal standards from -- 

21 Frank may remember it better than I do -- but it 

22 came in with the water heaters, air conditioners, 

23 heat pumps and furnaces, all in that same first 

24 batch. 

25 MR. STAS: I mean the general point comes 
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1 from the definition of energy conservation standard 

2 6291.6.a, where it says “a performance standard.” 

3 That’s where the genesis of this is, and we’ve had 

4 this in many of our rulemakings, so I think you’re 

5 aware of that history. But we would appreciate your 

6 comments on why you think this case is a different 

7 case. In that if you were to analogize to these 

8 HSPF, that would be a good -- 

9 MR. SACHS: Thank you, Eric. The only 

10 reason I bring it up is just that it might make 

11 sense. 

12 MR. STAS: We’re always looking for good 

13 solutions that work well within the confines of the 

14 statute. 

15 MR. BROOKMAN: Yeah, thank you. Craig. 

16 MR. MESSMER: Craig Messmer. I guess I 

17 probably don’t need to say it, but I will anyway. 

18 Our reference system should be 1.2 inches. We’re 

19 pretty happy with that. So I recommend that you 

20 continue it. 

21 MR. BROOKMAN: Thank you. 

22 MR. JASINSKI: So the reference system is 

23 also useful in helping to determine exactly where 

24 the procedure should specify the determination be 

25 made. As we’ve heard, it’s difficult to pinpoint 
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1 specific external static pressures, so instead of 

2 requiring manufacturers to try to target those 

3 specific operating points, DOE is proposing that 

4 determinations be made at three -- three separate 

5 determinations be made per rated air flow control 

6 setting. One at 0.1 inches water column, the second 

7 at an ESP that’s equal to the applicable reference 

8 system divided by two, and an ESP between the 

9 applicable reference system ESP and 0.1 inches water 

10 column above the reference system ESP. And the 

11 reason the language is broad here is because there 

12 are multiple reference system ESPs that are 

13 proposed, so hopefully these instructions allow for 

14 a universal approach to each of those different 

15 scenarios. 

16 The result is that three determinations 

17 are made in each of three of the rated air flow 

18 control settings, which results in a total of nine 

19 determinations required to generate the proposed 

20 metric FER for any given residential furnace fan. 

21 Coming back again to our example of an 

22 actual model. I brought back the electric 

23 consumption curves, and this is just a general 

24 overview of all the measured data that is required 

25 to calculate FER for a particular model. You’ll see 
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1 that three rated air flow control settings which are 

2 the top curves, the black curve which is the 

3 truncated reference system curve with the operating 

4 points labeled with the black dots to show at which 

5 -- to identify at which points we want to take -- or 

6 at which points we want to use the electrical 

7 consumption. And then, following down from those 

8 black dots you’ll see a provided black circles which 

9 represent the electrical consumption measurements 

10 that will be used in the calculation of FER. 

11 So now that we have all the measured data, 

12 the question becomes how do we calculate FER and use 

13 the power measurements that were identified to 

14 calculated estimated annual electric energy 

15 consumption. And DOE is proposing to do that, as I 

16 mentioned earlier, by proposing -- estimating 

17 national average operating hours for each of the 

18 rated air flow control settings, constant 

19 circulation, heating, and cooling. 

20 So DOE used the following equation to 

21 establish or to estimate national average heating 

22 and cooling fan operating hours. And I’ll just walk 

23 through this equation. So the hours are equal to 

24 fan on time ratio -- and I apologize, this looks 

25 like it’s two separate variables, but in fact, that 
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1 is not a minus sign, it should be a hyphen, so 

2 that’s one single ratio -- so, the fan on time ratio 

3 times the average annual energy use, which is 

4 adjusted by a weather factor to account for weather 

5 variations over a period of time, divided by the 

6 input energy or input capacity in the cases of 

7 heating and cooling. 

8 To estimate the national average operating 

9 hours for constant circulation, DOE used two reports 

10 that provided survey results of homes in Wisconsin 

11 and Minnesota related to their habits and use of 

12 constant circulation. DOE used this data with a few 

13 adjustments to account for factors that -- for 

14 certain factors that the Wisconsin and Minnesota 

15 data results are higher than what would be typical 

16 of the national average hours for a number of 

17 reasons. First of all, well the first two reasons 

18 are closely related. Because Wisconsin and 

19 Minnesota residents have a high awareness of indoor 

20 air quality issues, the building codes in those 

21 states are more stringent when it comes to 

22 infiltration, so those homes typically have lower 

23 air infiltration than the average home in the United 

24 States, so for those combined reasons, the survey 

25 results -- people in Minnesota and Wisconsin will -- 
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1 DOE expects will use constant circulation a lot 

2 more, so DOE wanted to account for that. 

3 And then the last point there is that 

4 Wisconsin and Minnesota homes are located in a 

5 northern climate region, which is not indicative of 

6 the climate of other climate regions, and so that’s 

7 another factor that contributes to the fact that 

8 homes in Wisconsin and Minnesota may use constant 

9 circulation more than in say, the hot dry region in 

10 the south. 

11 MR. BROOKMAN: Let’s just pause just for a 

12 moment. 

13 MR. JASINSKI: Sure. 

14 MR. BROOKMAN: Jim Vershaw, you have your 

15 hand raised. Is your question related to these -- 

16 the earlier slide? 

17 MR. VERSHAW: Yes, the earlier slide. 

18 MR. BROOKMAN: Please. Go ahead. 

19 MR. VERSHAW: As far as using three points 

20 to characterize the curve, I firmly believe that we 

21 ought to be ... get an accurate fit ... might be able to 

22 be more particular point ... five points for the curve 

23 which ... 

24 MR. BROOKMAN: Jim, I don’t know what you 

25 can do, but you’re kind of breaking up, we’re 
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1 hearing two out of every three words. We’re getting 

2 the gist of it, but if you can do -- 

3 MR. VERSHAW: Well, I’m hearing myself 

4 back on the phone. That better? 

5 PARTICIPANT: Talk some more, it sounds 

6 better. 

7 MR. BROOKMAN: Yes, it sounds better, just 

8 keep going, and loudly. 

9 MR. VERSHAW: I want to go back -- 

10 MR. BROOKMAN: That’s better, yes, go 

11 ahead. 

12 MR. VERSHAW: I think we ought to use five 

13 points to describe the curve, you shouldn’t use 

14 three points. That’s the first point. Second 

15 point, was -- okay, I forgot. 

16 MR. BROOKMAN: Okay, you can return to 

17 that and we’re going to continue with the 

18 presentation point and then we can back up as 

19 necessary. So, Sam, back to you. 

20 MR. JASINSKI: Thanks. Were there any 

21 questions or comments related to this slide? 

22 MR. STANONIK: Frank Stanonik, AHRI. On 

23 your equation, okay now the text says test by 

24 national average heating and cooling fan operating 

25 hours. And the equation talks about an input 
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1 capacity. Which input is that? By heating input or 

2 by cooling? 

3 MR. JASINSKI: For furnaces, it would be 

4 your input heating capacity -- I’m sorry, for the 

5 heating hours it would be the furnace input heat 

6 capacity. 

7 MR. STANONIK: I guess I asked my question 

8 badly. So the question -- my question really is, so 

9 this hours you would calculate separately heating 

10 hours and -- 

11 MR. JASINSKI: No, I’m sorry. So these 

12 calculations, these values are based on national 

13 averages, so these aren’t values that you would 

14 calculate specific to each model. We did these 

15 calculations based on national average data and have 

16 proposed a specific value for hours that would be 

17 used across all products. 

18 MR. STANONIK: Okay. So then you use the 

19 heating input? 

20 MR. JASINSKI: Yes, the national average, 

21 I believe it was from RECS 2005, the average heating 

22 input capacity. 

23 MR. STANONIK: Okay. And then the second 

24 question is, the second bullet talks about, okay, 

25 you used the results from information in Wisconsin 
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1 and Minnesota to estimate national average. So 

2 first of all, I’m assuming that meant you made some 

3 adjustments to adjust for the fact that you’re 

4 getting data from, let’s say, a northern climate -- 

5 MR. JASINSKI: Yes. 

6 MR. STANONIK: -- to somehow reflect an 

7 average, a national average, and part of that is 

8 using national average energy use? 

9 MR. JASINSKI: No, the specific 

10 adjustments that were made were, for instance, well, 

11 the resulting average -- weighted average based on 

12 survey responses for say, the Minnesota or 

13 Wisconsin, I mean, specifically DOE expects that 

14 those results are 50 percent higher than what would 

15 be typical for other homes in the northern region, 

16 and 90 percent higher than what would be typical in 

17 the south hot, dry region. 

18 MR. STANONIK: Okay. And if you’ll 

19 indulge me one last question on this slide, and this 

20 is a serious question because I’m not familiar with 

21 those Wisconsin, Minnesota studies, but so in these 

22 homes where people were using the fan for constant 

23 circulation, was there any let’s say entry in the 

24 data that might identify when those homes were 

25 perhaps opening windows in the temperate times? 
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1 MR. JASINSKI: I can’t say with 100 

2 percent certainty, but I don’t believe so. And just 

3 as a note, one of the backup slides, which I know 

4 there were some issues with the printouts, but if 

5 you access the presentation on line, there’s a 

6 backup slide, number 64, provides the details of how 

7 DOE translated the survey results into estimations 

8 of hours and used these adjustment factors. 

9 MR. BROOKMAN: Charlie Stephens. 

10 MR. STEPHENS: Charlie Stephens. Listen, 

11 Harvey made a point earlier that if you go back far 

12 enough that we think, based on our own limited data 

13 -- which we’re trying to get more of right now, we 

14 should have more data on this very shortly, which 

15 we’ll provide to the Department -- there’s a high 

16 correlation between circulation, or constant 

17 circulation and high end air filtration, electronic 

18 air filtration systems. That in the past it’s -- 

19 most people are circulating to filter the air. And 

20 I’ve learned that anecdotally by lots of 

21 conversations with contractors who recommend this, 

22 and program it, and their clients. So that’s -- I 

23 think that’s potentially true. 

24 I don’t know about the Wisconsin and 

25 Minnesota data, but in recent times, the code has -- 
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1 the national energy codes have clamped down on air 

2 tightness and ventilation may now be playing a 

3 larger role in the future, in other words, and there 

4 are a significant number of systems in our part of 

5 the world compared to what there used to be, where 

6 these systems are being timed to run for the 

7 purposes of ventilation and there is a fresh air 

8 inlet on the system. That’s a recent phenomenon, 

9 but it may be a forward looking phenomenon. We may 

10 see more of that. 

11 So I think what I didn’t find in the 

12 proposal here is a very good rationale -- I know we 

13 don’t have much data, but there’s not a very good 

14 rationale for your adjustment. And I really would 

15 be a lot happier if we could find some more data and 

16 get a better rationale for how we can estimate how 

17 accurate this figure you’re using is. If you are 

18 willing to tell us what we need to know in order to 

19 get that data, there’s some chance that I can get a 

20 lot more data, at least in our part of the world, if 

21 somebody tells me. I have the budget to do it. I 

22 just need to know -- I don’t want to bring you data 

23 that isn’t what you needed. But we really, I think, 

24 need a lot more data before we can nail this number 

25 down. I’m not very happy with kind of what I see 
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1 here as arm-waving. 

2 MR. BROOKMAN: Okay. Jim Vershaw is on 

3 the line. Jim, go ahead. 

4 MR. VERSHAW: Yes, Jim Vershaw here again. 

5 ... Go back to the ... data where we wanted to do five. 

6 The other point was that we feel that there should 

7 be latitude on where the data is taken. In other 

8 words, don’t make it exactly one, or exactly point 

9 three five, have a little bit of ... when you say five 

10 points ... we want to get well spread out data points, 

11 five should be just fine ... 

12 MR. BROOKMAN: Thank you. Jim, you’re 

13 still breaking up, I don’t know whether you’ve got 

14 some other alternative that you could use, or 

15 whether your cell phone needs to be charged or 

16 what’s going on there, but you can think on that. 

17 Did you hear most of that? 

18 MR. JASINSKI: Yes, I thought so. 

19 MR. BROOKMAN: Yes, I think we got most of 

20 it. 

21 MR. MESSMER: You’re clear on what he’s 

22 saying. He’s saying -- 

23 MR. JASINSKI: Instead of targeting point 

24 one, have some tolerance so you don’t have to hit 

25 that exactly -- 
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1 MR. MESSMER: Right, because it takes a 

2 while to get to any given test point. 

3 MR. BROOKMAN: Okay. That’s what I heard 

4 as well. Dave, you want to -- 

5 MR. WITTINGHAM: Yes, just to kind of 

6 reiterate what Jim was saying. There’s many systems 

7 when you go to the low end of the low end in regard 

8 to static, or high end, systems can become unstable, 

9 particularly when you’re trying to measure air flow. 

10 And the air measurement device, and the piece of 

11 equipment that you’re trying to measure, the 

12 stability of those can be real critical. 

13 MR. BROOKMAN: Okay. Good. 

14 MR. JASINSKI: Thank you. So moving on, 

15 DOE proposes a value of zero for hydronic air 

16 handler off mode operating hours, because DOE 

17 expects that hydronic air handlers are not typically 

18 equipped with a seasonal off switch, or the 

19 consumers will not turn off power to the hydronic 

20 air handler. There’s a definition provided for 

21 seasonal off switch which essentially states that “a 

22 seasonal off switch is a switch that cuts power to 

23 the product and results in a distinguishable 

24 difference between standby mode and off mode 

25 electrical energy consumption. 
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1 So the idea here is that DOE does not 

2 believe that hydronic air handlers typically have 

3 such a switch, and in effect there is no 

4 distinguishable difference between off mode and 

5 standby mode electrical energy consumption. 

6 And lastly, DOE estimates or proposes to 

7 estimate that the average annual standby mode fan 

8 operating hours is equal to the remainder of annual 

9 hours not assigned the other modes discussed: 

10 heating, cooling, constant circulation, or off mode. 

11 So all that translates to this table, and 

12 here are the results of those efforts. As you can 

13 see, in the heating mode, the estimate is 830 hours, 

14 constant circulation mode is 400 hours, cooling mode 

15 is 640 hours, off mode zero as I mentioned, and then 

16 the equation there for standby mode is essentially 

17 the total annual -- total hours in a year minus the 

18 hours that are estimated for the other modes of 

19 operation. 

20 Now you’ll notice that there are two sets 

21 of values, the single stage heating values that I 

22 just mentioned, but DOE is proposing to estimate the 

23 heating mode hours differently for multistage -- for 

24 units that have multistage heating. The difference 

25 being that the 830 hours that was estimated for the 
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1 single stage heating is divided by the heating 

2 capacity ratio, and the heating capacity ratio is 

3 the ratio of the output heat capacity in the low 

4 heat setting to the output heat capacity ratio in 

5 the high heating setting. 

6 And on the next slide, I’ll go into a 

7 little bit more detail about that, the methodology 

8 and the impacts of that. But does everybody have 

9 the summary of the estimate hours? 

10 So to go into detail about the multistage 

11 hours. DOE proposes to account for the differences 

12 in operation between single stage heating and 

13 multistage heating, or modulating heating units in 

14 its estimated annual heating fan operating hours. 

15 DOE finds that low heat setting -- in multistage 

16 units the low heat setting is typically -- typically 

17 accounts for 90 percent of heating operation time. 

18 And as a result, it requires more heating operation 

19 hours when compared to a single stage unit to 

20 provide the same total delivered heating in a given 

21 installation. 

22 So, as a result, DOE proposes to use the 

23 following equation to determine average annual 

24 heating operation hours for multistage and 

25 modulating furnace fans, which is to take the 830 
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1 that is estimated for single stage and divide it by 

2 that heat capacity ratio. So just for reference, an 

3 example of a heat capacity ratio would be a model 

4 where the low heat output -- low output heat is 

5 roughly 70 percent of the high output heat capacity, 

6 and that would result in heating hour estimate of 

7 around 1185 hours. 

8 So essentially, this is how DOE is 

9 accounting for the fact that multistage hearing 

10 units have a longer operating, fan operating time in 

11 the heating mode. 

12 So there’s lots of requests for comments 

13 regarding these -- the operating hours, with some 

14 specific comments, but the first on is generally 

15 whether those operating values are reasonable 

16 estimations of national average operating hours. 

17 And I’ll go back to the table so we can refer to 

18 them. 

19 MR. BROOKMAN: Aniruddh. 

20 MR. ROY: With respect to the studies that 

21 occurred in Wisconsin and Minnesota, I think these 

22 two states have the indoor air quality issues -- or, 

23 yes, indoor air quality issues, and so in the 

24 national average I feel it would be better if DOE 

25 also consider other states to give a better 
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1 representation of those hours, not just Wisconsin 

2 and Minnesota. So those are our comments. 

3 MR. BROOKMAN: Okay. Thank you. Greg. 

4 MR. WAGNER: I was going to say, looking 

5 at the circulation mode at 21 percent of the hours 

6 represented on the single stage heating, I’m a 

7 manufacturer, I’m going to target that for making 

8 sure that I have the lowest watt consumption in all 

9 the modes, so make sure I design something for that. 

10 It’s a big number out of that percentage of the 

11 total run time. 

12 The other thing is that the cooling mode 

13 is included in here, and as we covered earlier, 

14 that’s covered under the SEER calculation, so it’s 

15 already a regulated part of it. I think, going back 

16 to what we originally talked about definition, the 

17 heating mode should be the only one that is part of 

18 some regulatory action to evaluate what furnace fan 

19 performances, as per the mandate originally laid 

20 out. 

21 MR. BROOKMAN: Okay. Thanks. Craig. 

22 MR. MESSMER: Craig Messmer. We’re seeing 

23 a lot of the newer homes, very, very tight homes 

24 starting to have a lot more circulation hours than 

25 that. In fact, they may never shut off. So I don’t 
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1 know if you factored that into this equation. 

2 MR. BROOKMAN: This is nation-wide? 

3 MR. MESSMER: Right, I don’t know, maybe 

4 there needs to be something that’s stated for these 

5 new tight homes. The FER’s going to be grossly 

6 different. 

7 MR. BROOKMAN: Charlie Stephens. 

8 MR. STEPHENS: I’m getting ready to launch 

9 a study into that out in our area, but -- and that 

10 is true except that in our area they tend to be 

11 timed to meet ASHRAE 62.2 which is really what’s 

12 referenced in the code, and that tends to have them 

13 running timed at about eight hours a day, typically 

14 out where we are, in that mode. So whether or not 

15 that overlaps the heating and cooling function is 

16 another issue which we have to investigate. But I 

17 hope to have some good data on that -- that’s a 

18 separate study we’re about to launch. And I’ll 

19 provide the data. 

20 What I wanted to ask was, well there are 

21 two things. One is, how consistent are these with 

22 the kinds of values that we see in the test 

23 procedure for heating -- for furnaces, heat pumps 

24 and air conditioning in terms of weight averaging? 

25 You know, the ratings for -- I mean, I would hope 
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1 they would be somewhat consistent since some of 

2 these products are used in that very same mode 

3 sometimes in the very same climate zones. So I’m 

4 just pointing that out that they should be 

5 consistent. If they aren’t, if they’re radically 

6 different, then maybe we ought to think about why, 

7 making sure we know why. 

8 The other thing is, how these things are 

9 used makes a difference to me. We’ll get into the 

10 energy use here shortly, but I’m not very happy with 

11 energy use and using these numbers as an energy use 

12 metric. I think if they were used to weight average 

13 a fan efficiency, watts per CFM, CFM per watt or 

14 whatever, I’m happier with that, because I think you 

15 won’t be nearly as far off the mark with your 

16 average number at the end. 

17 The variation that we’re going to see in 

18 annual energy use is much larger than you’re going 

19 to see in the variation of the efficiency of the 

20 fan, I think, even using these weight average 

21 numbers to come up with a single national number. 

22 If it was a single national watts per CFM, you’re 

23 not going to be too far off, I think. But you’re 

24 going to be way off in Butte, Montana and Waco, 

25 Texas, if you try to put the same air handler in 
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1 those two places. The number that you come up with 

2 is going to be really, really, really way wrong in 

3 both of those places. And I don’t think it’s 

4 constructive to lead people to believe that it’s 

5 useful. Whereas, you won’t be nearly as far off if 

6 you’re publishing a single weighted average fan 

7 efficiency number, based on these same weightings. 

8 Just my two cents on that. 

9 MR. BROOKMAN: Okay. Thank you. 

10 MR. JASINSKI: So specific questions about 

11 some of those -- some of them mentioned. DOE is 

12 also requesting comment on whether hydronic air 

13 handlers are designed to provide multistage or 

14 modulated heat. This is just an instance where 

15 hydronic air handlers are relatively newly 

16 commercialized product and as we’ve discussed, there 

17 are a lot of variations, so DOE is requesting 

18 comment on whether those specific variations are 

19 commercially available or -- you can provide that in 

20 written comment if you can identify hydronic air 

21 handler models that provide multistage or modular 

22 heating. 

23 MR. BROOKMAN: Yes, okay, Charlie’s got 

24 some data. Okay. 

25 MR. JASINSKI: Another question is whether 
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1 or not the methodology presented for determining 

2 multistage heating hours is appropriate. 

3 MR. BROOKMAN: Craig. 

4 MR. MESSMER: Well, we have multistage 

5 hydronic air handlers, but we have no data on this. 

6 We didn’t know we needed to have any, so I’m not 

7 sure how we’re going to be able to reply to that 

8 other than saying that we have multistage air 

9 handlers. 

10 MR. JASINSKI: Sure. 

11 MR. BROOKMAN: Charlie, go ahead. 

12 MR. STEPHENS: Yeah, I’ll just -- 

13 multistage is -- you’re kind of maybe using the term 

14 a little off. It’s not necessarily multistage, but 

15 it is variable capacity. If you have a variable 

16 speed air handler, and we use the ones by the major 

17 manufacturers for this, with a hydronic coil, or you 

18 can order one from Area Brands that makes the Life 

19 Breath line -- they have a variable speed version of 

20 this thing. You can use an outdoor reset control on 

21 this thing to manage the pump for the hot water, or 

22 to manage the temperature of the hot water, and you 

23 can vary the heat being delivered to the house, and 

24 you can vary the air flow to match the temperature. 

25 And we’ve done a lot of projects like that in homes 
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1 that actually use them in that way, so it’s -- it’s 

2 not exactly multistage because there’s no burner, 

3 but you do manage the hot water in similar ways, 

4 either with the pump or the temperature of the 

5 water, and you can manage your air flow to hit, for 

6 instance, a delivered air set point temperature, 

7 which is frequently what’s done. So you should take 

8 that into account, I think. 

9 MR. JASINSKI: Thank you. That’s very 

10 helpful. 

11 MR. BROOKMAN: Craig. 

12 MR. MESSMER: Charlie brings up a good 

13 point. What are we talking about multistage? Are 

14 we talking about the heat generation portion of the 

15 system, in this case the boiler with setback 

16 controls? Or are we talking about just multiple fan 

17 speeds as being the stage? 

18 MR. JASINSKI: So similar to -- well, 

19 essentially the air flow control settings, and that 

20 goes back to tying -- DOE’s assumption that air flow 

21 control settings are typically designated for 

22 specific functions. So in product literature, DOE 

23 finds that different air flow control settings are 

24 designated for heat, and in the instances of a 

25 multistage units, one air flow control setting will 
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1 be designated for high heat output, and a lower one 

2 would be designated for a low heat output. So in 

3 the context of this proposed procedure, it would be 

4 the air flow control setting that’s designated for 

5 low heat. 

6 MR. MESSMER: Okay. Some systems, like 

7 heat pumps, for example, the capacity of the system 

8 changes not just with the air flow, but with the 

9 outdoor unit. Same thing with a boiler. Same thing 

10 with some other types of systems. So the percentage 

11 of low stage is going to be different than if you 

12 had just a simple air flow change, whereas maybe the 

13 water temperature stays the same in the hydronic 

14 coil. I’m not sure how to handle that, but it’s 

15 something we need to consider. 

16 MR. BROOKMAN: Harvey Sachs. 

17 MR. SACHS: Harvey Sachs, ACEEE. Sam, I 

18 think your use of the term is somewhat idiosyncratic 

19 in terms even of my limited understanding. I’m 

20 pretty sure we saw four speed PSC motors long before 

21 we had any significant penetration of modulating 

22 heating devices. And in fact, my understanding, 

23 which is not terribly good, but reasonable field 

24 experience, is that this was to match to static 

25 pressure to get the air flow you desired. That was 
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1 done very roughly. So that multistage to me, as an 

2 industry term, is about the energy source supplying 

3 to the coil, and it’s not about the fan settings. 

4 So I think you may well have confused several of us. 

5 MR. JASINSKI: Okay. Well, just that as -

6 - to repeat. Essentially, you know, Greg has 

7 brought this up multiple times in that the difficult 

8 task here is to essentially separate thermal 

9 performance from air flow performance. And within 

10 the confines of the statutory limitations that we’re 

11 working under, our goal here is to rate air flow 

12 performance. So in this context, DOE has made 

13 assumptions about how air flow control settings play 

14 into design decisions, and have come up with, based 

15 on what we found in -- from discussions, comments, 

16 and product literature, that in designing a fan to 

17 be used in these systems, so designing a fan to be 

18 used in a multistage system, for instance, that 

19 there is a relationship between the air flow control 

20 setting and a specific heating stage. So DOE here 

21 is not confusing the two, they’re simply asking and 

22 assuming, and asking about that assumption, that 

23 they are related, that in fact, when a manufacturer 

24 produces a multistage heating unit that has multiple 

25 heat outputs from the burner, that those outputs are 
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1 designated for a specific air flow control setting 

2 of the circulation fan. There’s a mapping going on, 

3 essentially, not that they’re the same entity. 

4 MR. SACHS: (off mic) Application 

5 specific. That’s about ... in my experience. 

6 MR. BROOKMAN: Charlie Stephens. 

7 MR. STEPHENS: I think it might just be a 

8 matter of terminology here. I mean we == when we 

9 look at an air handler, specifically, ignoring the 

10 heat source, we look at multispeed versus variable 

11 speed, typically, to sort of separate out the ones 

12 that you either have to wire for different tap 

13 speeds, or some of the dumber ECM products that 

14 actually look more like a multispeed PSC motor than 

15 a true variable speed motor. 

16 But I think the real difference in an air 

17 handler is you’ve got a lot more choices with 

18 speeds, typically, you’ve got a lot of dip switches 

19 that you can play with on a variable speed motor, 

20 versus a PSC or multitap motor. But, that being 

21 said, they respond differently, and they’re 

22 controlled differently. So the question is, in our 

23 mind, it’s a matter of control. Are you controlling 

24 to a single speed, or does the motor adapt to the 

25 conditions that it sees and the controls -- and this 
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1 gets complicated. This is where I think people 

2 earlier have pointed out, you know, that when you’ve 

3 got an air handler that adapts to what it sees in 

4 terms of external static or temperature, or its 

5 being controlled on another variable like outdoor 

6 air temperature or something like that, return water 

7 temperature, whatever you want to use, you get a 

8 more complicated paradigm, if you will. 

9 But I think, again, for the test procedure 

10 and giving this thing a rating, it just has to be 

11 rated at a certain air flow point and external 

12 static pressure point, regardless of what control 

13 settings were used to put it there. I think if you 

14 can just figure out how to rate the thing at those 

15 points using as few variables as possible, we’ll 

16 understand in the field how that plays out when we 

17 control it. 

18 MR. BROOKMAN: Okay. Jim Vershaw also has 

19 a comment or a question. Go ahead, Jim. 

20 MR. VERSHAW: Can you hear me this time? 

21 MR. BROOKMAN: Yes, sounds better. 

22 MR. VERSHAW: Well, I’ve only dialed in 

23 three times so I’m little bit late on the comment, 

24 but if you go back to -- I’m with the gentleman 

25 who’s questioning, who’s using the number of hours 
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1 in this whole calculation, and what’s the value that 

2 brings, because it’s an arbitrary number that’s 

3 supposed to be kind of representative of some place 

4 in the country, but it depends upon so many things. 

5 Why not just -- the performance of the appliance 

6 based on what the end condition? That gives you the 

7 thing without throwing in hours that confuses what’s 

8 really going on depending on where you are and how 

9 you’re using the problem. 

10 MR. BROOKMAN: Okay. 

11 MR. JASINSKI: So here -- 

12 MR. BROOKMAN: Harvey Sachs. 

13 MR. SACHS: Harvey Sachs, ACEEE. If I 

14 could be so bold as to translate Charlie Stephens 

15 and Jim Vershaw, I think you would find a lot of 

16 support for expressing this metric in watts per CFM 

17 instead of trying to do it in kilowatt hours per 

18 year. It may require a little bit of a stretch. It 

19 may require a lot of support. But I haven’t heard 

20 anyone defending the efforts to remove ourselves 

21 further from the data with a lot of assumptions and 

22 extrapolations to get this as annual energy 

23 descriptor instead of a steady state descriptor. 

24 MR. JASINSKI: Maybe this will become more 

25 clear when we provide examples, but the proposed 
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1 metric is actually in the units of watts per CFM. 

2 The estimate average annual energy consumption is 

3 normalized by the operating hours as well as the air 

4 flow in maximum air flow control setting, so the 

5 resulting metric will be in terms of watts per CFM. 

6 And I think that will become -- I’m going to provide 

7 an overview of the variations of the FER 

8 calculation, and then immediately after that show 

9 some examples of how FER will be calculated for 

10 specific models. So maybe that will clear up some 

11 confusion. 

12 MR. BROOKMAN: Going in that direction. 

13 MR. JASINSKI: Like I said, there are some 

14 variations of the FER equation. At the top I’ve 

15 provided general form, so FER here. As we stated 

16 previously, it’s just the estimated average energy 

17 consumption which essentially is the sum of 

18 operating hour -- the estimated operating hours 

19 times power consumption in all the rated modes, 

20 depending on the product, normalized -- again, 

21 divided by the sum of the operating hours for the 

22 rated modes, times the maximum air flow control 

23 setting, and all that is multiplied by 1000 to put 

24 the final resulting metric in the units of watts per 

25 1000 CFM, which I think a lot of manufacturer are 
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1 familiar with. I think that’s how fan performance 

2 is characterized for the CAC rulemaking. 

3 So the first variation that I’ve provided 

4 is for non-hydronic furnace fans. Again, for non5 hydronic furnace fans, standby and off mode 

6 operation are being excluded, because those -- 

7 consumption in those modes is being covered in 

8 ongoing rulemaking activities for products that fall 

9 into those categories. Here you can see the 

10 specific variables that follow the general form 

11 under those constraints. 

12 Next is heating and cooling hydronic 

13 furnace fan, to designate them from heating only 

14 hydronic furnace fans. And here I’ve highlighted in 

15 red that standby mode and off mode are included here 

16 and it’s important to note not only is annual energy 

17 consumption in those modes included in the 

18 numerator, but a key difference is that the 

19 estimated operating hours is included in the 

20 normalization factor in the denominator here also. 

21 And later on in the rating metric examples and 

22 comparisons, the impact of that will come to light. 

23 Following that is the heating only 

24 hydronic furnace fans variation. Excuse me, before 

25 I go on, you’ll notice that this is actually IFER 
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1 which stands for integrated fan efficiency rating, 

2 and the reason is because standby and off mode here 

3 are integrated, pursuant to EPCA when possible, any 

4 measurement of standby and off mode should be 

5 integrated in the overall metrics. So that’s the 

6 reason there is a variation for integrated fan 

7 efficiency rating. 

8 So, then the last variation, heating only 

9 hydronic furnace fans. Again, DOE expects that 

10 there are some hydronic furnace fan products out 

11 there that are not intended to be paired with a 

12 cooling system, which may or may not be accurate. 

13 But in that particular variation you’ll notice that 

14 there are no terms for accounting for cooling 

15 operation. So these are the different variations of 

16 the FER equation. 

17 MR. BROOKMAN: Yeah. So questions on the 

18 equations? We’re about to describe some rating 

19 examples. So maybe that will be illuminating. 

20 MR. SACHS: In the third equation -- 

21 MR. BROOKMAN: Harvey Sachs. 

22 MR. SACHS: Harvey Sachs. -- we have a 

23 term CH times E-sub-max. I assume that’s E-sub 

24 cooling instead? 

25 MR. JASINSKI: No, it’s intentionally max 
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1 because, as proposed earlier, DOE is proposing to 

2 rate in the maximum air flow control setting, which 

3 expects is designated typically for cooling 

4 operations. 

5 MR. SACHS: Thank you. So this refers 

6 back to the earlier ambiguity. Thank you. 

7 MR. JASINSKI: Sure. 

8 MR. BROOKMAN: Charlie. 

9 MR. STEPHENS: Charlie Stephens. Just a 

10 quick -- how are we differentiating between heating 

11 and cooling hydronic and heating only? 

12 MR. JASINSKI: So DOE found that there are 

13 certain hydronic air handlers that are not designed 

14 to be paired with an external evaporator coil, 

15 therefore the thinking is that the fan is not 

16 designed to provide cooling, which would -- I’m 

17 sorry, go ahead. 

18 MR. STEPHENS: Well, actually, we’re using 

19 those with cooling, and in fact you can do that, do 

20 cooling when you use a chilled water -- you use 

21 chilled water from a heat pump to do that. You 

22 don’t use an external coil, you would only use -- 

23 MR. JASINSKI: Right. 

24 MR. STEPHENS: So we use a fan speed that 

25 did cooling. 
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1 MR. JASINSKI: I guess the important 

2 question is then, is there a need for a distinction? 

3 I guess what we’re trying to do is prevent using the 

4 IFER for hydronic furnace fans that provide heating 

5 and cooling for something that might not be designed 

6 to do that. 

7 MR. STEPHENS: The difference -- this is 

8 Charlie again -- the difference comes in when you 

9 either have an external refrigerant coil on the 

10 system or you don’t. But the fan speed, the fan 

11 speed may be the same. You may be doing cooling in 

12 the maximum -- what you call the maximum E-max, but 

13 the external static that it’s working against may be 

14 different, depending on whether you’re doing it with 

15 a DX coil or you’re doing it with chilled water. I 

16 don’t know how you’re going to make that 

17 distinction, but we’re doing both of those things 

18 actually, so -- 

19 MR. JASINSKI: Thank you. 

20 MR. STEPHENS: It depends on whether you 

21 have a boiler or a heat pump, or a water heater or a 

22 heat pump doing the heat. 

23 PARTICIPANT: Sorry, to address Charlie’s 

24 situation, you could just have one formula and if 

25 there’s no cooling, CH goes to zero, and the formula 
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1 looks like the bottom one, right? 

2 MR. STEPHENS: Yeah, well, I don’t know 

3 how the inter -- I haven’t thought about how the 

4 interplay goes between the external static. You 

5 have an extra coil in once case and you don’t have 

6 an extra coil in the other. So the values that -- 

7 yeah, the E values are, you know, it’s a matter of 

8 whether it’s E-heat, which is one coil, or an add-on 

9 coil I think is the differences in the E you’re 

10 using. 

11 MR. JASINSKI: Just to provide an analogy 

12 I guess that might clarify so that we can -- so that 

13 when you provide written comments you understand 

14 what DOE is trying to understand here is that, 

15 analogous to maybe a furnace manufacturer who is 

16 designing a furnace that is not intended to be 

17 paired with a cooling coil, they might design that 

18 fan differently than they do for one that is 

19 designed to have a cooling coil. So that’s what 

20 we’re trying to do here. Does there need to be a 

21 distinction for a hydronic air handlers or any 

22 products that may not be -- the fan design is not 

23 intended to provide cooling. It would fall into one 

24 of these bins, but the question is we don’t want to 

25 use the wrong equation for, say, a hydronic air 
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1 handler, if it exists, that is not intended to 

2 provide cooling. 

3 MR. BROOKMAN: Charlie. 

4 MR. STEPHENS: One quick -- I don’t know 

5 of any that are not designed to do cooling. All the 

6 ones that we use like -- and I don’t like to mention 

7 names -- but like Tranes 4TEE (ph) air handlers, 

8 Carrier’s FE-4s, those. We use those. They’re 

9 designed to do cooling or whatever, and the Life 

10 Breath product is designed to do cooling as well, so 

11 all the ones we use will or will not do cooling, 

12 depending on what you want. 

13 MR. JASINSKI: Okay. Thank you. 

14 MR. BROOKMAN: Craig. 

15 MR. MESSMER: Craig Messmer. It really 

16 depends on what the goal is of this rating metric. 

17 If the goal is to get the field to determine what 

18 the energy use is on an annual basis, then having 

19 separate equations sort of makes sense, because you 

20 don’t have cooling in one, okay. But if the goal is 

21 to be able to rate across the board, how do you 

22 compare a non-hydronic furnace fan FER with a 

23 heating only hydronic furnace fan IFER? How do you 

24 know which one’s more efficient? 

25 I would propose that you have just one 
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1 equation and that’s it. And just plug in some 

2 standard values for cooling or whatever if it 

3 doesn’t have it. That allows you to compare 

4 different products across different product types. 

5 We’ve already kind of agreed, sort of, that none of 

6 this is going to give anybody any indication of what 

7 their energy use is going to be during the year, so 

8 I think we can take that goal off the table. So 

9 that’s what I would recommend. 

10 MR. BROOKMAN: Greg. 

11 MR. WAGNER: Yeah, I’ll just dovetail 

12 that. We talked a lot about that, and some of this 

13 calculation and manipulation, you get the hours and 

14 all the other stuff. We’re just doing a lot of work 

15 to accomplish something that it sounds like a lot of 

16 folks don’t want to get, and it’s not necessarily 

17 going to be helpful to their consumer, because 

18 ultimately, they need to know what is the cost of 

19 energy per whatever that function of that device is. 

20 And we’re losing sight of that by doing a lot of 

21 this extraneous calculation, manipulation of data. 

22 MR. JASINSKI: Okay. I’ll move on. 

23 Rating Examples and Comparison 

24 Next I want to provide some rating 

25 examples to hopefully get everyone a little bit more 
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1 familiar with the fan efficiency rating and how it 

2 compares across different types of products. 

3 So this is something you’ve seen before. 

4 Again, using the same non-weatherized gas, non5 condensing furnace fan with a four speed PSC motor, 

6 we’ll use the proposed annual operating hours, and 

7 this table essentially walks through the calculation 

8 of estimated annual energy use. So you can see that 

9 in the power column, those are the measurements that 

10 are taken at the operating points which are 

11 identified by the reference system, multiplied by 

12 the estimated annual operating hours. You can see 

13 the annual consumption by function in the last 

14 column. And then in the bottom, the total. 

15 I’ve provided a reiteration of the FER 

16 equation here, and then below that you can see the 

17 actual values for each of those different factors. 

18 So at the top, the annual -- the estimated annual 

19 energy consumption, normalized by air flow in the 

20 maximum air flow control setting, which in this case 

21 is 1050 CFM, and that is multiplied by the total 

22 annual rated operating hours, which in this case 

23 does not include standby or off mode, so it’s 

24 essentially just the sum of the annual operating 

25 hours, multiplied by 1000, which results in a fan 
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1 efficiency rating for this particular model of 376 

2 watts per 1000 CFM. 

3 So next -- I don’t have a depiction of the 

4 -- or a graphic of the measured data, but this is 

5 for a heating and cooling hydronic air handler 

6 furnace fan that uses an ECM motor. So again, the 

7 first column shows the power which was identified 

8 using the same methodology as before, multiplied by 

9 the annual operating hours. And I’ve highlighted in 

10 red here that the standby operating hours and power 

11 consumption are considered for this particular 

12 product, the hydronic air handler, which you can see 

13 impacts the total annual operating hours, as well as 

14 the annual energy consumption. 

15 So again, same representation in words of 

16 what’s going into the integrated FER calculation 

17 here. And then below, the numbers that correspond 

18 to those things. Of note here, you’ll notice that 

19 the annual rated operating hours amounts to the 

20 total annual rated operating hours, whereas in the 

21 previous example that number was much lower because 

22 it excluded standby operating hours, and again, 

23 multiplied by 1000 to result in an integrated FER 

24 rating of 45 watts per 1000 CFM. 

25 To bring these two together and to provide 
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1 a little bit more context, essentially what this 

2 graph shows is both of those ratings -- it shows the 

3 contribution in each mode to the total of that 

4 rating. And so the one all the way to the left is 

5 the non-weatherized gas, non-condensing furnace fan 

6 that uses a four speed PSC that we’ve seen 

7 throughout the presentation. All the way to the 

8 right is the example that I just presented of the 

9 hydronic air handler heating and cooling that uses 

10 the ECM. And then to bridge the gap, to show -- 

11 because the difference between the hydronic air 

12 handler is one that it includes standby, but also 

13 that it also uses a different motor type, I provided 

14 a non-weatherized gas, non-condensing example that 

15 uses an ECM to show the comparison between PSC and 

16 ECM performance. And below, in case you missed any 

17 of that, I’ve provided information regarding how the 

18 acronyms match up to the specific types. 

19 MR. BROOKMAN: Dave. 

20 MR. WITTINGHAM: This is Dave with Allied. 

21 I think if you go back to the prior two slides, it 

22 really illustrates the problem of having two 

23 different measurement and metrics. That if you’re 

24 looking truly at fan performance, when you include 

25 the standby power, it really skews the number so 
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1 from a comparison standpoint, it is going to cause 

2 confusion, and even adds to the value of the, in a 

3 negative way, of the metric itself. Because if you 

4 look at the power that it’s using when it’s moving 

5 air, in the first scenario, it’s kind of in between 

6 the values. This number is below any of the values 

7 that when it’s truly moving air. Thank you. 

8 MR. BROOKMAN: Frank Stanonik. 

9 MR. STANONIK: I think Dave hit a key 

10 point. If this is supposed to be a fan efficiency 

11 measurement, and the key idea is how much energy I’m 

12 using to move air, that’s the function of this 

13 product, then injecting the standby laws really 

14 doesn’t fit that descriptor. And in this particular 

15 case, it just being allocated here, where in the 

16 other cases it got allocated somewhere else. I mean 

17 standby loss for this equipment is somewhere, but it 

18 seems so arbitrary to stick it here and drag that 

19 number down in this one instance. 

20 MR. BROOKMAN: Charlie. 

21 MR. STEPHENS: Charlie. I would agree. 

22 I’m a little bit ambivalent about how you do it, but 

23 I think you need to make things consistent. You 

24 either need to bring the standby power in from the 

25 other air handlers besides hydronic, and I think 
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1 most manufacturers already have that number as long 

2 as the test methods are consistent from what they 

3 have to do to get that from like a Carrier FE-4, 

4 whatever, 4TEE, whatever, then you should bring it 

5 in here. Or, you should separately list it out, or 

6 take it out of that one. Because I really do think, 

7 again, all those hours and everything, your hourly 

8 allocations are going to change depending on where 

9 you are, and that -- even the standby number is the 

10 residual of whatever’s not active mode, essentially, 

11 and that varies. 

12 So I agree with the other commenters that 

13 that really should not be in one type of air handler 

14 and not in the others, or maybe it should be 

15 separate for the hydronic, because as you say, it’s 

16 not covered anywhere else, but it needs to be apples 

17 and apples. 

18 MR. BROOKMAN: Okay. Harvey. 

19 MR. SACHS: I would look forward to 

20 comments from industry, including the motor 

21 manufacturers. What we’ve seen with a number of 

22 other technologies is the standby power is the 

23 result of other design considerations, when standby 

24 power was not considered something that was an 

25 important design variable. And if it is somehow 
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1 made visible in ways that matter to the customer of 

2 the advanced motor, we may see that the 75 or 80 

3 kilowatt hours a year go down a great deal. It may 

4 well be, as we’ve seen with power supplies, 

5 analogous to power supplies in some respects for 

6 computers, that we can get the functions we want and 

7 save money with some redesign that only gives us 

8 three watts. 

9 So I’m certainly sympathetic to the view 

10 that incorporating that standby into the annual 

11 energy consumption. It’s something that’s hard to 

12 do and decreases the value and can only be justified 

13 if that’s the only construction of the statute that 

14 can be allowed. Otherwise, separately reporting 

15 that would certainly be a whole lot better as a 

16 signal for innovation and approaching our energy 

17 efficiency goals as a nation. 

18 MR. BROOKMAN: Okay. Thank you. Final 

19 comments on 49 and the preceding slides that build 

20 up to that? 

21 MR. JASINSKI: Doug, I have one specific 

22 question. One thing that’s not represented here is 

23 that some of the impacts that we’re pointing out as 

24 being less than desirable to some, between the 

25 hydronic air handler rating here and the non-
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1 weatherized gas, from including standby, might also 

2 be characteristic of a comparison between a single 

3 stage and multistage unit, because if we go back 

4 here, the calculation for the annual heating hours, 

5 that 830 would actually be divided by that heat 

6 capacity ratio. So that 830 would increase, like I 

7 said before, something typical might be around 1185, 

8 and the result would be that the total for say, a 

9 multistage -- this is a single stage I believe -- 

10 the total for a multistage might be a little bit 

11 larger than that. And again, it would cause a 

12 discrepancy in the comparison. 

13 So one question is whether or not 

14 normalizing by the total annual operating hours, or 

15 the same number of hours regardless of how you come 

16 to that total, would be beneficial as opposed to 

17 calculating them for each specific model? 

18 Essentially eliminating differences in the 

19 denominator. Something to think about. 

20 MR. BROOKMAN: I think include in your 

21 comments. Greg, go ahead. 

22 MR. WAGNER: Certainly that 8300 hours or 

23 8760 number of hours versus 1800 hours skews that 

24 data hugely, and since you’re only running it at 11 

25 watts in the standby mode, it does a huge disservice 
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1 to have two numbers that are ostensibly supposed to 

2 be comparable, not being in the same ballpark. So 

3 something has to be adjusted, the hours, standby 

4 mode, something to take away that factor. 

5 MR. BROOKMAN: Charlie. 

6 MR. WAGNER: I would say the last thing is 

7 in circulation mode, the same thing holds, since it 

8 is a significant amount in this particular case, 

9 you’d want to drive the circulating watts down 

10 considerably to, you know, you may not do anything 

11 about the other modes, but you drive those watts 

12 down and you’d have much better FER, yet it’s not 

13 necessarily a better product. That’s not a good 

14 factor. 

15 MR. BROOKMAN: Charlie. 

16 MR. STEPHENS: Yeah, I just would add to 

17 what Harvey said, I agree with what he said about 

18 separating it out so it’s not trivialized. But the 

19 other thing is standby is particularly egregious 

20 everywhere because it provides no service to 

21 anybody. It’s just power consumption for nothing. 

22 And we should really be willing to invest a couple 

23 of bucks to actually fix that. And I don’t think we 

24 will, I mean, if you bury 75 kilowatt hours in 700, 

25 it’s not going to be a big number, but if you 
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1 separated it out and say, look, this could be 25 

2 instead of 75, and you multiply that times millions. 

3 I mean that gets to be a power plant or two. So we 

4 really need to be able to focus on that. 

5 MR. BROOKMAN: Okay. Are we shifting 

6 gears? 

7 MR. JASINSKI: Yes, I’m going to -- 

8 MR. BROOKMAN: I’d like to invite everyone 

9 to stand up and just stretch for a moment while 

10 we’re shifting gears here. And you can stay 

11 standing. Now we’re going to hear from Detlef 

12 Westphalen. Actually Deet-lev (ph) Westphalen. 

13 Certification, Compliance and Enforcement Overview 

14 MR. WESTPHALEN: Detlef Westphalen, yes, 

15 with Navigant. Sam and I had a fight about how many 

16 of the slides that he’d allow me to present, and it 

17 wasn’t many. There might be a reason that he wanted 

18 me to present these couple here, but anyway. 

19 Certification, compliance and enforcement. 

20 There’s really only one slide here with some request 

21 for feedback. I realize what’s not mentioned here 

22 is that -- and it’s listed in the NOPR -- that there 

23 are also some changes associated with what’s 

24 required -- proposed to be required in a 

25 certification report for these products. And I’m 
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1 not going to dwell on that unless somebody wants to 

2 get into that. 

3 But this slide is about sampling plan for 

4 residential furnace fans. DOE proposes to create a 

5 new section for sampling plan specifications for 

6 manufacturers to determine the certified ratings, 

7 and DOE proposes to adopt the same statistical 

8 sampling procedures that are applicable to 

9 residential furnaces. Those are in sections 18 and 

10 they also refer to section 11 of 10CFR429. 

11 And this third bullet, I’m just going to 

12 read it. DOE believes product variability and 

13 measurement repeatability associated with the 

14 electrical energy consumption measurements proposed 

15 for rating residential furnace fans are similar to 

16 those associated with electrical energy consumption 

17 measurements required for residential furnaces. As 

18 I said, I’m just going to read that and then request 

19 comment. 

20 MR. BROOKMAN: Yes, Aniruddh. 

21 MR. ROY: So the interpretation as far as, 

22 you know, what EPCA’s guidance has been for DOE is 

23 to open up the scope to various products. But when 

24 it comes down to certification requirements, it’s 

25 narrowed down to furnaces, residential furnaces. 
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1 That’s something we fail to understand because in 

2 the case of confidence limits, you have different 

3 confidence limits for residential central air 

4 conditioners and heat pumps, and what is specified I 

5 think under residential furnaces is about 97.5 

6 percent. So these products are subject to different 

7 confidence limits as far as DOE certification is 

8 concerned. So we think it’s kind of unfair to just 

9 extend the 97.5 to all the products, because 

10 currently the manufacturers are rating central air 

11 conditioners, I believe, to 90 percent. So that 

12 should be taken into consideration. 

13 Another factor we hear with AMCA 210 is 

14 that Section 4.1.2 specifies a random uncertainty of 

15 -- or measured random uncertainty of 95 percent. So 

16 I think DOE should take that into consideration also 

17 before coming up with a confidence limit of 97.5 

18 percent. In fact, my question originally before you 

19 stated that slide was, has DOE evaluated the 

20 feasibility of the 97.5 confidence limit thus far on 

21 the proposed FER metric? 

22 MR. WESTPHALEN: Well, I would say at this 

23 point, Sam mentioned that there was some testing 

24 conducted, and obviously the scope of the testing 

25 that’s going to be conducted for such a rulemaking 
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1 is much more limited than all of the testing that a 

2 lot of the manufacturers do in their own labs. DOE 

3 would certainly welcome data that would provide some 

4 indication of what the confidence levels perhaps 

5 should be if the proposed levels aren’t appropriate. 

6 MR. BROOKMAN: Dave. 

7 MR. WITTINGHAM: Yeah, this is Dave from 

8 Allied. While the measurement of the electrical 

9 power should be fairly stable and accurate, although 

10 there are some special requirements for variable 

11 speed motors -- you have to have true RMS type 

12 devices which some manufacturers may or may not 

13 have. When you introduce the measurement of air 

14 flow into this equation, the variability of air flow 

15 measurement is considerably higher. The measurement 

16 uncertainty, the tolerances of motors, fans, the 

17 manufacturing process, there is a fairly high degree 

18 of variability in the air flow of measurement. 

19 Greg, I mean, your area of expertise is to 

20 build air moving devices, and Greg can allude to the 

21 difficulty of consistent and accurate air 

22 measurements. And I think that is something that 

23 DOE needs to consider in this, moving forward, that 

24 the measurement uncertainty tolerance of components 

25 within this. We need to have a reasonable tolerance 
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1 in this and absolutely the rating and enforcement 

2 confidence limits need to be the same. We have an 

3 issue, a unitary small (ph), where we have a 

4 different rating confidence limit and an enforcement 

5 confidence limit. I think that’s something that we 

6 should absolutely try to prevent here. 

7 MR. BROOKMAN: Greg. 

8 MR. WAGNER: As any of you that have 

9 conducted air flow measurements know, it’s difficult 

10 to get accurate, precise measurements. And even 

11 under laboratory conditions, as Aniruddh alluded, 

12 AMCA will define what some of those uncertainty 

13 confidence levels are. It’s much greater than what 

14 it is for what they do currently with the furnace 

15 testing where it is the temperature and a meter 

16 device to establish what that capacity is. That’s a 

17 fairly robust measurement system. When you go to 

18 measure air flow, it’s not as consistent, as Dave 

19 just outlined. That’s another reason, a good 

20 reason, for keeping with the standard that’s already 

21 used and accepted in terms of measuring output and 

22 capacity of products, which DOE recognizes in terms 

23 of the AFUE, and adding on something of an 

24 electrical consumption with that, because you 

25 already have an understanding of what that tolerance 
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1 and uncertainty window is for measurement of 

2 capacity. 

3 MR. BROOKMAN: Okay. Harvey. 

4 MR. SACHS: Thank you, Detlef. My brain 

5 is getting old and I don’t remember the statistical 

6 sampling procedures for residential furnaces. But 

7 it brings me back to my initial, not my initial, but 

8 one question earlier to Eric and Mohammed, and this 

9 section is called certification, compliance and 

10 enforcement. What is going to be certified? This 

11 IFER or FER determined measurement -- no, 

12 calculation -- or the underlying measurements that 

13 support it? What is the manufacturer going to be 

14 held responsible for? 

15 And I ask this in part because it directly 

16 relates back to the question whether we’d rather 

17 have five air flow measurements occur at different 

18 static pressures, or rather have multiples -- 

19 multiple measurements at three? So there’s just an 

20 awful lot of ground to be covered, I think, before 

21 any of us has an understanding of what is being 

22 asked. 

23 MR. WESTPHALEN: I think part of what 

24 you’re referring to, Harvey, is the proposed 

25 requirements for certification reports. And I kind 
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1 of brought this up here with me, a cheat sheet, so I 

2 didn’t have to memorize it. 

3 MR. SACHS: I don’t have it. 

4 MR. WESTPHALEN: And I’ll read it. So for 

5 -- and it’s different for furnace fans used in 

6 hydronic air handlers, but for furnace fan used in 

7 HVAC products other than hydronic air handlers, the 

8 represented value of the fan efficiency rating, the 

9 FER, the maximum air flow capacity at the reference 

10 system external static pressure, in cubic feet per 

11 minute, whether the product has multistage or 

12 modulating heating, and if so, the maximum and 

13 minimum output heat capacities in British thermal 

14 units per hour. And whether the HVAC product is 

15 designated for use in manufactured homes. 

16 MR. SACHS: But these are all data you 

17 require to be revealed. Not all of these are 

18 certified. 

19 MR. WESTPHALEN: These are all items that 

20 are proposed to be required as part of the 

21 certification report. 

22 MR. SACHS: Okay. So in terms of my 

23 question, the FER would be a required disclosure 

24 subject to compliance, but none of the underlying 

25 data would need to be disclosed to the Department, 
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1 although many of us would hope that they would be in 

2 the engineering literature from the manufacturer. 

3 MR. WESTPHALEN: That’s correct. Usually 

4 DOE reserves the right to inspect test report data 

5 which would have -- 

6 MR. SACHS: Yeah. Thank you. 

7 MR. BROOKMAN: Terry. 

8 MR. SMALL: I have one comment -- this is 

9 Terry Small -- that you might want to consider, is 

10 the idea that maybe the manufacturer be allowed to 

11 obviously have the choice of testing each model. 

12 Other possibility might be to use an AEDM, perhaps, 

13 to rate models. Just a thought, if you’ve 

14 considered that, or would consider that as part of 

15 your rulemaking. 

16 MR. WESTPHALEN: I’m not aware that there 

17 has been discussion as part of the discussion 

18 specifically on this test procedure development 

19 regarding allowing AEDMs. But I would imagine 

20 that’s something that DOE could consider. And 

21 certainly if your written comments could elaborate a 

22 little bit more, that might be helpful. 

23 MR. KHAN: This is Mohammed, DOE. Detlef 

24 just kind of took the words out of my mouth. And 

25 I’m sure that you will submit comments, and I hope 
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1 that you could elaborate on that option, explaining 

2 what potential benefits there would be, right, 

3 versus the burden that’s involved. What kind of 

4 measurements are there going to be to try to 

5 validate such a program, how reliable it’s going to 

6 be, so forth and so on. Those are the kinds of 

7 things that DOE would need to be able to consider in 

8 making that kind of determination. 

9 MR. BROOKMAN: Charlie. 

10 MR. STEPHENS: Charlie Stephens. I just 

11 would add that we have done quite a bit of 

12 laboratory testing of heat pump systems, which 

13 obviously involve the air handlers, and it involved 

14 testing the air flows, and we were quite pleased 

15 that we were able to validate pretty much all the 

16 manufacturers’ fan curves, as well as their ratings 

17 in the lab. So we -- whatever the manufacturers are 

18 doing to measure the air flow and develop their fan 

19 curves seem to be what we found if we went to 

20 measure the same things, almost across the board. 

21 So I don’t -- we’re not very discouraged with what 

22 the manufacturers produce in their own literature. 

23 So we know it’s possible, and when we actually go to 

24 measure it, we get the same numbers, oddly enough, 

25 which is encouraging to us. 
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1 So I think this is actually already 

2 happening in some places. And as hard as it is to 

3 measure, we must be measuring pretty much 

4 identically to the manufacturers. We had four 

5 different manufacturers’ equipments in the lab, and 

6 several different capacities, and we didn’t really 

7 find anything off the mark when we were doing our 

8 own work. So somebody’s doing fairly consistent 

9 work out there, and I don’t have any reason to 

10 suspect that we couldn’t continue that. 

11 MR. BROOKMAN: Dave. 

12 MR. WITTINGHAM: Just a comment on that, 

13 and I think the manufacturers do make every effort 

14 to publish accurate air flow data. But when you 

15 look at something that’s held to a 97.5 percent 

16 tolerance limit, it’s a completely different row. 

17 And that’s what this is advocating. 

18 MR. MESSMER: And Charlie, it’s Craig. I 

19 can echo that, that’s the challenge. What is that 

20 confidence limit? And we test per AMCA standards 

21 as described there. We have oftentimes testing in 

22 comparison to the manufacturers, and occasionally 

23 there are differences in the amounts that are given, 

24 and we test, you know, hundreds if not thousands of 

25 units annually, and I would just say that I would 
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1 have a very strong problem with meeting anything 

2 close to 97 percent. 

3 MR. BROOKMAN: Let me inquire on this 

4 point, because I think Aniruddh referenced a number, 

5 but maybe it’s late in the day -- I thought that’s 

6 all I heard. Would the two of you suggest what the 

7 confidence level should be? 

8 MR. WITTINGHAM: Well, I think -- this is 

9 Dave with Allied -- I think at the high side, it’s 

10 probably a 90 percent confidence limit. I mean 

11 that’s what we have in place for the air 

12 conditioning side. But actually, I think there’s 

13 some work that would need to be done to validate 

14 repeatability of this over a section of products 

15 before I could give a full answer to that. 

16 MR. BROOKMAN: Frank? 

17 MR. STANONIK: If you could go back to the 

18 slide that actually has the FER calculation -- I 

19 don’t want to use it as an illustration, but that 

20 one, yes. I mean, one of the byproducts of the very 

21 -- the current significant discussion going on about 

22 certification and enforcement is that at least our 

23 members have certainly become quite a bit more 

24 appreciative of the significance of the confidence 

25 limits. And I think because of that, to answer a 
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1 question like this, as Dave mentioned, we probably 

2 would want to do -- try and do a much more rigorous, 

3 I call it, air analysis, to come up with let’s call 

4 it a documented number, as opposed to the historical 

5 practice, which was kind of, yeah, that kind of 

6 looks good. I’ll just tell you, I’m not aware of 

7 any data that supported any confidence limits for 

8 any of the equipment that we deal with today. They 

9 were just numbers that seemed to fit. 

10 But in this case, if you’re looking at, 

11 you know, you’ve got, as an example, you’ve got the 

12 Emax of the cooling hours, you’ve got the -- you 

13 have at least three electrical measurements, and 

14 then you have the air flow measurement. 

15 PARTICIPANT: I don’t mean to interrupt, 

16 but there’s actually nine measurement points that 

17 are being proposed, and then there’s a curve fit 

18 based -- 

19 MR. STANONIK: Okay. So you have nine 

20 electrical -- okay, nine electrical -- 

21 PARTICIPANT: Nine measurements. 

22 MR. STANONIK: Nine measurements and in 

23 terms of what’s done today, okay, so it makes some 

24 reference to -- well, today we measure electrical 

25 consumption on a furnace at the same confidence 
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1 limits. Well, yeah, but again, that’s kind of -- 

2 because that’s the cards we were dealt. But 

3 especially for something like this, we can’t answer 

4 your question right now because we’re probably going 

5 to have to look and say, try and do to the best of 

6 our skills here and maybe we hire some outside 

7 skills, a true air analysis and say, okay, if I had 

8 to do this like in this manner and really account 

9 for all the possible measurement errors, what does 

10 the confidence come out at? And I have no idea. 

11 Well, I’ll take that back. I’m pretty sure it’s not 

12 going to be 97.5 percent confidence limit. 

13 MR. BROOKMAN: Can you do it fairly 

14 quickly, Frank? 

15 MR. STANONIK: Not me, but if we need to, 

16 we can probably find somebody that can. 

17 MR. BROOKMAN: Do you have -- 

18 MR. STANONIK: Well, I’m sorry, Doug. The 

19 key is going to be identifying what we would agree 

20 are reasonable errors on those measurements. 

21 MR. BROOKMAN: That’s what I was thinking. 

22 And I was wondering if you have the kind of 

23 specification here in math form that now allows you 

24 to check against these formulas and the like. 

25 MR. STANONIK: I’m going to defer to 
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1 Aniruddh here, because he’s been talking to the 

2 manufacturers about this one more than I have. 

3 MR. ROY: Aniruddh Roy, AHRI. I’m not 

4 sure if we’ll be able to come up with a proposal by 

5 the comment deadline, but I would encourage DOE 

6 that, in the final rule, to at least perform a study 

7 rather than just refer to part 429.18 because that 

8 pertains to furnaces, and use that as a 

9 justification for the confidence limits for 

10 electrical measurements, because it’s significantly 

11 different, as you’ve heard from everyone over here 

12 at the table, it’s significantly different from the 

13 AFUE calculation. 

14 MR. WESTPHALEN: Sure. 

15 MR. BROOKMAN: Charlie, and then to -- go 

16 ahead. 

17 MR. STEPHENS: Harvey first. 

18 MR. BROOKMAN: Yeah, Harvey first. 

19 MR. SACHS: Harvey Sachs, ACEEE. I just 

20 want to caution us that we’re using the terms 

21 confidence interval and even error analysis somewhat 

22 loosely. There is a significant danger that we 

23 start talking about confidence bands that are two24 sided, and we are adamantly opposed to punishing a 

25 manufacturer for putting out a product that performs 
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1 better than it’s certified to do. So it does matter 

2 in terms of the confidence intervals, whether we’re 

3 doing a one-sided or a two-sided error analysis. 

4 MR. BROOKMAN: Okay. Charlie. 

5 MR. STEPHENS: Yeah, Charlie Stephens. In 

6 our work in the HVAC world, we strive for a 90 

7 percent confidence interval, and we’re generally 

8 quite happy with that unless we can identify a 

9 potential source of systematic bias. In which case 

10 we may try to go for 95 percent. We never look for 

11 more than 95, but 90 we find in our work for 

12 predicting equipment performance, is adequate 

13 because by the time you pile on application-specific 

14 factors, those things are washed out. So we’ll see. 

15 I’m optimistic that we can get to 90 percent, but I 

16 wouldn’t be pushing very hard for anything more than 

17 that. 

18 MR. BROOKMAN: Okay. Thank you. Jim 

19 Vershaw is on the line. Jim, you’re next. 

20 MR. VERSHAW: To Charlie who mentioned, 

21 though, that manufacturers were doing a good job was 

22 exactly why we use ASHRAE 37, not 51. In terms of 

23 confidence level, 97.5 is going to be ... if the motor 

24 were -- 

25 MR. BROOKMAN: Jim, we’re really losing 
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1 you now, try something different here. 

2 MR. VERSHAW: Is this better? 

3 MR. BROOKMAN: No -- keep talking, let’s 

4 try it. 

5 MR. VERSHAW: Okay. If you do -- 97.5 

6 isn’t going to work, 90 might, but I haven’t got 

7 data to prove it, but I know 97.5 is going to take 

8 at least three samples of everything to make the 

9 numbers come in line. 

10 The other big issue that we have with DOE 

11 certification versus enforcement is that the 

12 certification rules are different many times than 

13 the enforcement rules, and in many cases the tests 

14 that you use to get your certification would 

15 actually fail the enforcement. So a lot of work has 

16 to be done there in order to get that pulled 

17 together. Thank you. 

18 MR. BROOKMAN: Thank you. We got all of 

19 that, that came through clear. Thank you. Okay. 

20 So additional comments on these points? Did you 

21 have anything else you wanted to cover, Detlef, on 

22 this series of issues? 

23 MR. WESTPHALEN: No, I think it was just 

24 the one slide plus the request for comment, and we 

25 move on to closing remarks, which I assume -- 
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1 MR. BROOKMAN: Yes. The Department of 

2 Energy, as is typical, has made a Xerox copy of the 

3 business cards of attendees, and also I’m going to 

4 hand out this evaluation form. Please take a few 

5 moments to fill it out. 

6 And as Detlef mentioned, now is an 

7 opportunity for anybody that wishes to do so to make 

8 closing remarks, raise issues that you don’t think 

9 have been adequately covered during the span of the 

10 day. Terry first. 

11 Closing Remarks 

12 MR. SMALL: Terry Small with Mortex. I’d 

13 just to just make two comments in general, and one 

14 of them being just the cost for particularly the 

15 small manufacturer to be able to perform all the 

16 necessary testing on what would be a, maybe, a small 

17 volume of actual units being sold in a given year. 

18 So Greg has just kindly reminded me that a 

19 true AMCA certified unit, you can have them build a 

20 wind tunnel for you -- it’s about eight, ten feet in 

21 diameter and 40 feet long or something, looks like a 

22 rocket ship. I’m wondering that if we do an error 

23 analysis, and we look at the sensitivity, or maybe 

24 accumulate tolerances and all that, if there’s any 

25 possibility we could possibly look at maybe a 
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1 different way to get the CFM value. Maybe more in 

2 the line with a temperature rise calculation, you 

3 know, like could be used in the field, would be used 

4 in the field, which might be substantially quicker 

5 and thus less expensive. Maybe require less capital 

6 equipment. It would be probably much more 

7 achievable for a smaller manufacturer. 

8 And I guess that I’m just thinking back to 

9 all the field data that was on external static 

10 pressure that was collected. I’m assuming that how 

11 was the CFM information developed on all of the 

12 field data? Was that just with a hot wire 

13 anemometer or a for velocity, or how was all the -- 

14 or how was the CFM, on a temperature rise basis? 

15 MR. BROOKMAN: Charlie. 

16 MR. STEPHENS: No, just -- we use what’s 

17 called a twofold plate that actually slides into the 

18 filter slot in the unit, and it’s proven to be 

19 pretty accurate. It’s been verified against 

20 laboratory measurements to be very close. 

21 MR. SMALL: For CFM measurement? 

22 MR. STEPHENS: Right, for CFM measurement. 

23 MR. SMALL: And of course I’m embarrassed 

24 to say I’m not really aware of that particular 

25 device, but for instance, could a small manufacturer 
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1 use that device in our lab without having to buy 

2 $140 or $200,000 AMCA-certified wind tunnel to get 

3 the measurement? I guess my closing comments are 

4 that I think if you’re making tens of thousands of 

5 each model a year, you can amortize the cost to do 

6 all this testing, you know, as Jim Vershaw was 

7 saying, it looks like to him at 97.5 percent 

8 confidence level, you’ll have to do probably at 

9 least three tests per model. For a manufacturer 

10 that’s making a few hundred of a particular model a 

11 year, that will be absolutely prohibitive. So we 

12 might as well just -- we’ll have to drop the model, 

13 drop the models or whatever, do something different. 

14 Thank you. 

15 MR. BROOKMAN: Harvey Sachs. 

16 MR. SACHS: Terry, my other role was a 

17 small manufacturer, although not this industry. I 

18 think if you check in with AHRI and Craig Messmer 

19 sitting next to you, the advocates, I think, have a 

20 pretty good record trying to find ways that small 

21 manufacturers can compete fairly, and niche products 

22 can compete fairly. And we’re all ears. We didn’t 

23 come to the table to try to put you out of business. 

24 MR. SMALL: Terry Small again. Well, you 

25 know, I’m thinking that what came to my mind was, 
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1 you know, we all have a furnace stand and then using 

2 a temperature rise methodology to get CFM value at 

3 low speed and a CFM value at high speed. Certainly 

4 you calculate into a CFM value that could be used in 

5 the formula. And I don’t have a feel for the 

6 repeatability or the accuracy. But certainly 

7 something like that, running two or three tests 

8 would be not that much of a problem in coming up 

9 with something that looked like it was, you know, 

10 when you lay out the -- or you do the formulas, tied 

11 with a reasonable confidence interval, maybe 90 

12 percent, I think could be maybe very feasible for 

13 the smaller guys. But I’m just not sure about -- 

14 the way the NOPR is written exactly, whether it’s 

15 going to be feasible for the smaller manufacturers. 

16 MR. SACHS: Harvey Sachs again. There are 

17 various waiver procedures, and I certainly don’t 

18 talk ever for DOE, but there are ways of doing the 

19 combination. I hadn’t thought about temperature 

20 rise, but when you brought this up what occurred to 

21 me was put a long duct in front of the unit and a 

22 flow hood. So a flow hood and an electrical 

23 measurement and, you know, you might make me happy. 

24 I don’t know if you’d make DOE happy. 

25 MR. SMALL: This is Terry again. I’m 
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1 thinking that if, you know, we’re talking about the 

2 test procedure here. We’re getting ready to put the 

3 test procedure in concrete. I’m wondering if it 

4 could be demonstrated by a small manufacturer that 

5 we could get good results with something that’s not 

6 a $200,000 AMCA wind tunnel. Would there be -- and 

7 we could show DOE maybe that we could even validate 

8 our model and we could use that to perhaps, on an 

9 AEDM, to simulate. I just wonder if DOE would 

10 consider that as another option or possibility. 

11 MR. KHAN: This is Mohammed Khan, DOE. 

12 And I actually planned to say what I’m about to say 

13 at the very end anyway, but. Those kinds of ideas, 

14 alternatives to what has been presented and proposed 

15 here today, is something that we want to hear about. 

16 So in your comments summarizing many of the comments 

17 that you’ve already made here today, in addition to 

18 that, maybe you could include any kind of 

19 alternative approaches that you think would be very 

20 viable, make more sense, less burdensome, more cost21 effective, then we certainly want to know about it. 

22 So it’s something that we will, in fact, consider. 

23 So please submit that. 

24 MR. BROOKMAN: Eric Stas. 

25 MR. STAS: I have one follow up question 
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1 for you. You talk about buying a wind tunnel. What 

2 if you go to the third party testing and use 

3 somebody else’s wind tunnel and you all share it 

4 kind of thing? How much do the costs drop in that 

5 situation? 

6 MR. SMALL: Well, Eric, we did some very 

7 preliminary -- you know, we haven’t really had a lot 

8 of time to get ourselves organized for this, or at 

9 least my company hasn’t. And so we -- just to give 

10 you an idea, we started out, we just listed all the 

11 various models and all the possible capacities of 

12 heating device in the model. And we’ve got four or 

13 500 models, and this is at the first pass. And we 

14 were thinking also, it might take a day if we did it 

15 ourselves, but it would take a shift if ITS, if a 

16 third party did it too. And so you’re looking at a 

17 lot of testing. 

18 Now, we make an electric furnace that has 

19 a bunch of different capacities of strip heaters, 

20 you know, five kw, eight kw, ten kw, 50 kw -- and 

21 quite frankly, I don’t believe that the FER value is 

22 going to be any different, depending on how many 

23 heating elements -- I’m talking about electrical 

24 heating elements -- that you’re inserting into the 

25 furnace. So maybe instead of 400, we might be 
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1 looking at 100, but you’re still looking at a 

2 tremendous amount, whether you paid -- if you paid 

3 an outside third party, you’ll have estimated about 

4 $2000 I believe here, so that would certainly be a 

5 couple of hundred thousand dollars. It’s going to 

6 be expensive, one way or another. 

7 The problem is, if we were selling several 

8 hundred thousand units a year, then you’re looking 

9 at, you know, a fairly small amount per unit. But 

10 if you’re selling 5000 units a year, or 2000, and 

11 you have all these different models -- by the way, 

12 we build our products strictly to order. So we wait 

13 for the customer to order it. We have a lot of 

14 options. Some of the kw’s on an electric furnaces 

15 we probably never built. But it’s there in the 

16 catalog if they wanted, you know, a seven kw, we 

17 could make that. So you’re going to force us to 

18 have tested the 7 kw even though we may never sell 

19 it. Because I doubt if you would want us to take 

20 the order first and then test it later. 

21 So I think for the smaller -- I think for 

22 smaller manufacturers, this could be problematical, 

23 and I don’t necessarily think, you know, it’s not 

24 going to add anything to the consumer, really. In 

25 fact, It may take somebody like us off the market, 
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1 you know, who will do the odd combination of heating 

2 devices and all that. So I just think that ought to 

3 be taken into consideration. We’ll make some 

4 comments on it. 

5 MR. BROOKMAN: Thank you. Aniruddh. 

6 MR. ROY: Aniruddh Roy, AHRI. I just want 

7 to supplement what Terry said in terms of the 

8 manufacturer testing burden. With regards to 

9 furnaces first, and then I’ll expand it to other 

10 products. For the longest time, furnaces, you know, 

11 the federal descriptor was the AFUE metric. The 

12 AFUE metric is still there, but now, manufacturers 

13 are also subject to standby and off mode 

14 requirements, and you have the FER rating, which is 

15 specified at different static pressure measurements 

16 outside of ASHRAE 103 and federal test procedure. 

17 And of course you have the air flow measurements 

18 also which are required in order to establish the 

19 FER metric. 

20 In addition to that, manufacturers have to 

21 conform with what’s going on in Canada for the 

22 furnace fan rating which is a totally different 

23 metric, so that’s going to add an additional burden. 

24 We encourage DOE to try and harmonize and 

25 create a metric which essentially can be used all 
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1 over North America, not just in the US. And also 

2 consider the confidence limits. Because now if 

3 manufacturers are required to conform with the 97.5, 

4 there are other products that have confidence limits 

5 that are different, and so that could also pose an 

6 additional test burden overall on manufacturers. So 

7 those are our closing remarks. 

8 MR. BROOKMAN: Thank you. Additional 

9 closing remarks? Yes, Frank. 

10 MR. STANONIK: Frank Stanonik, AHRI. It’s 

11 more a question then, just because I lost track of 

12 it. Obviously we’re going to be interested in 

13 sharing the slides with members who weren’t here, a 

14 copy of slides that does have the equations on it 

15 will be available where? 

16 MR. KHAN: Mohammed Khan, DOE. Frank, 

17 perhaps you may have come in -- I think you came in 

18 a little bit late, and you may have missed my 

19 comment about that problem. First, I apologize that 

20 the printing came out the way it did. But on the 

21 DOE web page the presentation is there, so you can -

22 - it is available, yes. 

23 MR. STANONIK: Very good. 

24 MR. BROOKMAN: Yes, Craig. 

25 MR. MESSMER: Craig Messmer. First, I’d 
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1 like to thank the Department for having this 

2 meeting. I thought it was pretty good from my 

3 perspective. I thought I was heard. I’m just going 

4 to leave it with this. I hope this is not the last 

5 time we have a chance to have an input into this 

test procedure, that July 30th 6 isn’t the last time we 

7 get asked what do we think. Thank you, and see you 

8 again. 

9 MR. BROOKMAN: Thanks. Harvey Sachs. 

10 MR. SACHS: I’d like to thank everybody, 

11 but particularly Jim Vershaw who put up with this 

12 awful system for a whole day. 

13 MR. BROOKMAN: Dave, then Greg. 

14 MR. WITTINGHAM: Again, I would like to 

15 thank the Department and everyone for their 

16 participation. I think the number -- most of the 

17 topics have already been touched upon. The burden 

18 is obviously a sensitive issue with the 

19 manufacturers as well as the tolerance enforcement 

20 criteria. But I think I would strongly recommend 

21 that whatever the Department look at, as we look at 

22 a possible modification that allows integration of 

23 this test procedure with existing AFUE or a 

24 modification of that test, that when a unit is being 

25 tested, you can pick up another point or two, if E-
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1 sub-b is not sufficient, to pick up another point or 

2 two within that test process, without forcing 

3 another whole test setup to gather the data. I’d 

4 appreciate it. 

5 MR. BROOKMAN: Thank you. Greg. 

6 MR. WAGNER: I too would like to echo the 

7 thanks. It’s been an enjoyable day. I also thank 

8 the Department of Energy for ensuring job 

9 opportunities for fan guys like myself in the 

10 future. And Mrs. Wagner thanks you for that as 

11 well. 

12 Seriously, this is a good process. I 

13 would ask that you take a look at some of the 

14 proposals that have been put forth to try and reduce 

15 the amount of burden of testing that goes with 

16 adding a new metric. I think what the goal is to 

17 get some measure of what that furnace fan 

18 performance is, can be accomplished well within 

19 what’s being done today, in a manner that is useful 

20 and consistent, to be able to distinguish between 

21 good products, poor products, and to drive energy 

22 efficiency going forward. 

23 And from there, output, after you figure 

24 out what the test method is, then you can start 

25 putting some idea around what the confidence levels 
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1 would be, as someone indicated earlier, without 

2 really knowing what these test process is, there is 

3 a lot of uncertainty about the measurements, not 

4 just the process itself. 

5 With that, I echo what Craig said. I hope 

6 this is not the last opportunity to make the comment 

7 in addition to our written comments, because I think 

8 there is a huge opportunity here to put forth a good 

9 test standard that would be a limited amount of 

10 burden, but a great deal of useful information for 

11 all involved. 

12 MR. BROOKMAN: Thank you. Final comments? 

13 So then, for my part, I will just thank you. I 

14 thought we had a very, very constructive day, and 

15 I’ll turn it back to Mohammed for closing remarks. 

16 Closing Remarks from DOE 

17 MR. KHAN: Mohammed Khan, DOE. I’m just 

18 going to say thank you. We heard a lot of comments 

19 and opinions which I think the Department certainly 

20 appreciates. And I’m also going to reiterate the 

21 fact that, again, your comments are important. We 

22 need to have them. And when you submit those 

23 comments, please be sure to include in detail, 

24 additional alternatives that we heard, we touched on 

25 today. And I can assure you that we will consider 
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1 them in full. So with that -- 

2 MR. BROOKMAN: We should thank those that 

3 joined us via the web. 

4 MR. KHAN: Absolutely. 

5 MR. BROOKMAN: And hope this worked for 

6 you and the Department’s always looking for ways to 

7 improve access to these proceedings, so let them 

8 know about that as well. 

9 MR. KHAN: Thank you. 

10 MR. BROOKMAN: Safe travels to everyone. 

11 Applauds(Whereupon, at 3:53 p.m., the 

12 meeting in the above captioned matter was 

13 adjourned.) 

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 REPORTER'S CERTIFICATE

 This is to certify that the attached proceedings 

before: 

U.S. DEPARTMENT OF ENERGY 

In the Matter of: 

 

NOTICE OF ROPOSED RULEMAKING PUBLIC MEETING ON 

RESIDENTIAL FURNACE FANS TEST PROCEDURE 

 Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law 

Judge or the Agency. 

 Further, I am neither counsel for or related to 

any party to the above proceedings. 

 

 

Wendy Greene 

 Official Reporter 

Dated: June 20, 2012