PUBLIC HEARING ON 

Commercial Warm Air Furnace Test Procedures and Efficiency Certification, Compliance 

and Enforcement Requirements for Commercial Heating, Air Conditioning and Water 

Heating Equipment 

January 2'7,2000 

OPENING REMARKS 

Good morning. I'm Cyrus Nasseri, senior program manager and team leader for the 

commercial equipment team within the Office of Building Research and Standards here at'the 

Department of Energy (DOE). The others joining me today are Edward Pollock, Jr., Director of 

the Office of Building Research and Standards, Stanley Liu and Steve Treado of the National 

Institute of Standards and Technology, Edward Levy from the Department's Office of General 

Counsel, and Mark Friedrichs from the Ijepartment's Office of Policy and International Affairs, as 

well as several of my colleagues from DOE. 

On behalf of the Department, I would like to thank you all for taking the time to 

participate in this public hearing. We will be addressing DOE'S proposals for commercial warm 

air furnace test procedures and for efficiency certification, compliance, and enforcement 

requirements for all of the covered commercial heating, air conditioning and water heating 

(HVAC & WH) products. The format of this public hearing is designed to enable interested 

parties to present oral comments on these proposals, and to facilitate clarification, discussion, and 

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EE-RM/TP-99-450 COMMENT 02EE
an exchange of ideas as to these comments. 

Today's hearing will consist primarily of two distinct parts. In the first part, the 

Department is seeking comments on all facets of the proposed rule for commercial warm air 

furnace test procedures, including comments on the ASHRAE referenced test standards, the 

definition of thermal efficiency, the test procedures for the measurement of energy efficiency, and 

other test standard topics. In the second part, we seek comments related to the proposed rule on 

the certification and enforcement procedures for all of the covered HVAC & WH products, 

including comments related to certification, the Alternative Efficiency Determination Method 

(AEDM), the Voluntary Independent Certification Programs (VICP's), the provisions on 

non-participating manufacturers, and other certification and enforcement topics. 

In addition, you may offer comments on any other pertinent issues that you wish to bring 

to DOE'S attention. 

The comments received here today, along with comments submitted during the written 

comment period, will assist the Department in developing the final rules for commercial warm air 

furnace test procedures as well as commercial HVAC & WH product compliance, certification 

and enforcement provisions. 

I am the presiding officer for the workshop, and our own Jim Raba will facilitate and set 

the guidelines for conducting the workshop. 

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EE-RM/TP-99-450 COMMENT 02EE
In approximately two weeks, a complete copy of the transcript will be available for 

inspection and copying at the Department of Energy's Freedom of Information Reading Room 

located in Room 1 E-190. Anyone wishing to purchase a copy of the transcript may make 

arrangements with the court reporter. 

To provide the Department with as much pertinent information and as many views as can 

be reasonably obtained and to enable interested persons to express their views, the workshop will 

be conducted in accordance with the following procedures. 

We will begin with introductions and then review the agenda. We invite you to add issues 

you think are important but not already covered. Following the agenda review, we will entertain 

any general statements participants wish to make, and then we'll move to the discussion of topics 

on the agenda. As to each topic concerning the proposed commercial warm air furnace test 

procedures, Stan Liu will make a brief presentation and I will summarize any written comments 

we have received to date. Then participants can make any prepared statements on that topic, 

members of the panel will ask any questions they have, and we'll open the floor for questions and 

discussion. We'll move through each topic identified by the Department in the same way, and try 

to do the same for the topics that you might add to the agenda. We will follow a similar approach 

in the second part of this workshop, where Steve Treado will make presentations regarding the 

topics on the certification, compliance, and enforcement provisions for all of the covered 

commercial HVAC & WH products, followed by statements, questions and discussion. 

We should have ample time to raise and discuss all important issues. We would ask, 

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EE-RM/TP-99-450 COMMENT 02EE
however, that all participants refrain fiom making prepared statements of more than 5 minutes on 

any point or overly lengthy follow-up remarks, so that everyone gets the floor time they need. 

Our facilitator will enforce this ground rule, and will also limit debate when speakers' points have 

been made and are clear. 

In formulating the proposed rules we are discussing today, we have considered all oral 

and written comments that you, the stakeholders, gave to us earlier, and the published notice 

discusses the reasons for incorporating or not incorporating any of your significant 

recommendations. For your information, we will soon issue separate notices of proposed 

rulemaking regarding the test procedures for commercial water heaters, boilers and air 

conditioners. We intend to set up a single set of provisions on compliance, certification, 

enforcement and certain other general matters, and they would apply to all the covered 

commercial heating, air conditioning and water heating equipment. Therefore the other notices 

proposing test procedures for such equipment will not address these subjects. 

Questions are welcome throughout any of our presentations unless you are advised 

otherwise. It may be necessary, however, to cut off debate on some topics to remain on schedule, 

although there may be time at the end of today's session for additional discussion of significant 

issues. I encourage everyone present to participate as much as possible so that we may get a full 

spectrum of opinions on these topics. 

The session is scheduled to adjourn today at 5:00 -- unless, of course, we finish early. 

Topics which have not been completely discussed by that time can be addressed in additional 

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EE-RM/TP-99-450 COMMENT 02EE
written comments which are due by February 28,2000. All written comments and data 

submissions will be available for public inspection at the DOE Freedom of Information Reading 

Room. The phone number is (202) 586-6020. 

Please send your written comments to Brenda Edwards-Jones here at the Department, 

referring to Docket No. EE-RMlTP-99-450, when you respond. We would like to have ten 

copies of your comments and any supporting data, along with an electronic copy of the comments 

or data using Word Perfect 8 for text-based information or Microsoft Excel 97 for data-based 

information. No faxed comments will be accepted. Anyone attending this hearing or submitting 

written comments will be added to our list for future mailings concerning the subjects of this 

rulemaking. 

Again, we appreciate the time and effort you have taken in preparing for this hearing, and 

we are pleased to receive your comments and opinions. Our purpose today is to listen to your 

views. 

I'd now like to introduce our facilitator, Mr. Jim Raba, who will review the agenda, 

provide some housekeeping details, and describe how we will conduct the meeting. 

Agenda Review - Jim Raba 

Followed by- Introduction of Stan & Steve for their presentation. 

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EE-RM/TP-99-450 COMMENT 02EE